OVERVIEW SURVEY OF THE
DRYCLEANING INDUSTRY
PEDCo ENVIRONMENTAL
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PEDCO ENVIRONMENTAL. INC.
P.O BOX 2O337
DALLAS. TEXAS 7522O
(214) 259-3577
TELEX (214) 254-4O21
OVERVIEW SURVEY OF THE
DRYCLEANING INDUSTRY
by
PEDCo Environmental, Inc.
Contract No. 68-01-4147
Task No. 101
John R. Busik, Project Officer
Robert L. King, Task Manager
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
DIVISION OF STATIONARY SOURCE ENFORCEMENT
WASHINGTON, D.C. 20460
March 1980
CORPORATE OFFICE
11499 CHESTER ROAD
CINCINNATI OHIO 45246
(513)782 47OO
CHESTER TOWERS
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DISCLAIMER
This report was furnished to the U.S. Environmental Protec-
tion Agency by PEDC0 Environmental, Inc., in fulfillment of
Contract No. 68-01-4147. The contents of this report are repro-
duced herein as received from the contractor. The opinions,
findings, and conclusions expressed are those of the author and
not necessarily those of the U.S. Environmental Protection Agency.
ii
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CONTENTS
Page
Figures iv
Tables v
Acknowledgment V I.
1. Introduction 1
2. Industry Characterization S
3. Control Technology and Factors Affecting Its
Enforcement 31
4. Methods of Identifying Sources and Quantifying
Emissions 42
References 61
Appendix Inventories of coin-operated, commercial, and
industrial drycleaning establishments and of
• perc emissions 63
iii
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FIGURES
Number Page
2—1 Commercial Perc Drycleaning Plant Flow Diagram,
With Paper Cartridge Filter and Carbon
Adsorber 10
2—2 Flow Diagram Of Industrial Drycleaning Operation 12
4-1 Drycleaning Industry Data Sheet 44
4-2 Clothes Processed Versus Perc Consumed By
Commercial Drycleaners In Dallas And Hamilton
Counties (1 to 4 Employees) 56
4-3 Clothes Processed Versus Perc Consumed By
Commercial Drycleaners In Dallas And Hamilton
Counties (5 to 9 Employees) 57
4-4 Clothes Processed Versus Perc Consumed By
Commercial Drycleaners In Dallas And Hamilton
• Counties (10 to 19 Employees) 58
4-5 Clothes Processed Versus Perc Consumed By
Commercial Drycleaners In Dallas And Hamilton
Counties ( 20 Employees) 59
iv
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TABLE S
Number Page
2-1 Summary List: Coin-operated Laundries and
Drycleaners In The United States, 1976 16
2-2 Summary List: Commercial Drycleaners In The
United States, 1976 16
2—3 Summary List: Industrial Laundries and
Drycleaners In The United States, 1976 17
2-4 Representative Emission Factors For commercial
Drycleaners 21
2-5 Representative Weights of Clothing Cleaned By
Commercial Drycleaners 22
2-6 Summary Of Emission Factors and Weight Of
Clothing Cleaned Per Establishment 24
2-7 Summary Of Estimated 1976 Perc Emissions From
Drycleaners (Mg) 26
2-8 Predicted Growth Patterns In The Drycleaning
Industry To 1980 (Number of EstablishmentS) 27
2—9 Perc Emission Factors Before and After Applica-
tion Of RACT, kg/100 kg Of Clothes 30
2—10 Projections of Controlled Perc Emissions (Mg) 30
4—1 Survey Of Dallas County Commercial Drycleaners
Using Carbon Adsorbers 47
4-2 Commercial Drycleaners With 1 to 4 Employees 49
4-3 Commercial Drycleaners With 5 to 9 Employees 52
4-4 Commercial Drycleaners With 10 to 19 Employees 54
4-5 Commercial Drycleaners With 20 Employees 55
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ACKNOWLEDGMENTS
This report was prepared under the direction of
Thomas C. Ponder, Jr., and Mazen Y. Anastas. Principal authors
were Mazen Y. Anastas, Herbert J. Belknap, Jean E. Carruthers,
Cynthia N. Harvey, K. Wade Mason, and Mary A. Taft. Task Manager
for the U.S. Environmental Protection Agency was
Mr. Robert L. King.
vi
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SECTION 1
INTRODUCTION
BACKGROJJND
The Clean Air Act Arnendn ents (CAAA) of 1977 required each
state to report to the U.S. EnvironnLental Protection Agency (EPA)
on all areas within the state as to the status of compliance with
National Ambient Air Quality Standards (NAAQS). Attainment and
nonattainment areas in each state with regard to the control of
major pollutants were listed in the Federal Register on I’ arch 3,
1978. According to the 1977 CAAA, nonattainment areas must
achieve compliance with NAAQS by December 31, 1982, with some
possible extensions to 1987.
In December 1978, a Control Technique Guideline (CTG)’ was
published for control of Volatile Organic Compounds (VOC) from
perchioroethylene (perc) drycleaning systems. Those industries
in areas where standards covering a particular pollutant are not
being met will be required to apply Reasonably Available Control
Technology (RACT), which is discussed in the guideline publica-
tion. Perc drycleaning systems constitute a significant VOC
source in urban areas.
On or before January 1, 1980, all states are required to
submit to the EPA proposed revisions of the State Implementation
Plan (SIP) reflecting RACT for perc drycleaning systems. Promul-
gation of the regulations is required by July 1, 1980. The new
regulations will involve state and local agencies with an indus-
try that to date has been involved in little or no air pollution
control enforcement. Previous state regulations pertaining to
organic solvents, specifically Rule 66 of the Air Pollution
Control District County of Los Angeles, California, and Part 205
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of the New York City Metropolitan Area, have always exempted perc
from emission limitations. Part 212 of the New York City Metro-
politan Area Regulations does provide some limitations to perc
emissions from drycleaning facilities.
PURPOSE AND SCOPE OF REPORT
A current inventory of perc drycleaning establishments in
the United States, and specifically in photochemical oxidant
nonattainment areas, is needed for evaluation of the enforcement
of RACT requirements, for long-range planning by EPA’S Division
of Stationary Source Enforcement (DSSE), and for use in operation
of regional and local programs.
This report includes an inventory of all U.S. drycleaning
establishments having Standard Industrial Classification (SIC)
codes 7215, 7216, and 7218. These represent establishments with
coin-operated facilities, commercial establishments, and indus-
trial establishments, respectively, which together constitute the
three major sections of the drycleaning industry. The inventory
gives the status (attainment or nonattainrnent) for photochemical
oxidants of each area. In addition to the demography, Section 2
includes a brief description of the industry, with definitions of
each SIC code and typical modes of operation in the three indus-
try sectors. The number of drycleaning plants and potential perc
emissions are projected for the years 1980, 1985, and 1990 from
base numbers. The base numbers were obtained from the 1976
County Business Pattern (CBP) publication 2 of the Bureau of
Census; from PEDC0 surveys of drycleaning establishments in
Dallas County, Texas, and Hamilton County, Ohio; and from the
CTC.
Section 3 describes the control technology for perc dry-
cleaning facilities and the factors affecting enforcement of
RACT. In addition, the enforcement aspects of the proposed model
regulation are reviewed. This is a preliminary overview of the
problems associated with application and compliance monitoring of
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RACT. More specific problems will be addressed in future phases
of this study on perc drycleaners.
Section 4 describes PEDC0’s methods of identifying emission
sources and quantifying emissions. The sources of information
are discussed, and results of the Dallas County and Hamilton
County surveys are given. Recommendations for future demographic
studies are also provided.
S JNIV1ARY OF FINDINGS
This survey indicates a total of 32,663 laundry and dry-
cleaning establishments located in the United States as of 1976.
Of the drycleaning establishments, the numbers using perc in the
three industry sectors are as follows: 5,179 in the coin-op
classification, 14,366 in the commercial classification, and 193
in the industrial classification. The total 1979 perc emissions
from all perc drycleaning plants is estimated to be 158,000 Mg
(174,000 tons). The number of drycleaners using other solvents
is as follows: 133 coin-ops using freon, 4,789 commercials using
naphtha, 798 commercials using freon, and 193 industrials using
naphtha.
The proposed regulations are intended to reduce vapor emis-
sions from the dryer exhaust, to reduce perc emissions from
leakage of liquids, and to reduce the perc content of waste
materials. Control technology includes the use of a carbon
adsorber or equally effective control device on the dryer ex-
haust, increased maintenance for detection and immediate repair
of leaks, and suitable operation of stills, muck cookers, and
filter cartridges to reduce the perc content of the waste mate-
rials before disposal. Coin-operated facilities and those with
limited space or steam capacity are exempt from installation of
the carbon adsorber.
Enforcement of the proposed regulations pertaining to limit-
ing the dryer exhaust emission may be difficult in the absence of
a relatively inexpensive continuous monitor for perc in the
concentration range of 10 to 200 ppm. Inspections for leakage
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and inspections to determine whether the operator is following
proper procedures to reduce perc contents of wastes are time con-
suming and may be impractical because the total number of sources
is very large. The difficulties may be circumvented by specify-
ing standards for each classification based on the rate of sol-
vent consumption per weight of materials cleaned or per number of
drycleaning cycles; such standards are referred to as “mileage”
standards.
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SECTION 2
INDUSTRY CHARACTER I ZATION
DESCRIPTION OF INDUSTRY
The perc drycleaning facilities of concern for this study
are three industries in the SIC Code 721 — Laundry, Cleaning, and
Garment Services:
o Coin-operated laundries and drycleaners (SIC code 7215)
o Drycleaning plants, except rugcleaning (SIC code 7216)
O Industrial launderers (SIC code 7218)
The services provided by these industries include cleaning of
apparel, household fabrics, and work uniforms.
Coin-operated Laundries and Drycleaning Establishments
( SIC 7215 )
Coin-Operated laundries (coin-ops) are defined as follows in
the Standard Industrial Classification Manual. 3
Establishments primarily engaged in the operation of coin-
operated or similar self-service laundry and drycleaning
equipment for use on the premises, or in apartments, dormi-
tories, and similar locations.
Coin-ops are distinguished from the commercial and industri-
al drycleaners in that the drycleaning equipment is activated by
the customer. Often the manager or attendant of the coin-op
assists the customer in drycleaning the clothes. Coin-ops are
normally part of a laundromat facility and can be operated on an
independent or franchise basis. They provide a low cost [ approx-
imately $1.10 per kg ($0.50 per ib) of clothes] 4 self-service
type of cirycleaning without pressing, spotting, or other services
provided by commercial drycleaners. A typical coin-operated
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drycleaning establishment processes approximately 9,050 kg
(20,000 ib) of clothes per year, for an average annual gross
income of $10,000 per year. 5 Coin-ops are located primarily in
urban areas.
Perc is the predominant drycleaning solvent used by the
coin-ops, accounting for 97.5 percent of the drycleaning sy-
stems. 1 Fluorocarbon solvents account for the remaining 2.5
percent of the coin-op systems; no coin-operated machines use
petroleum solvents because of their flammability.
The drycleaning units used in the typical coin-ops are
predominantly self-contained and automatic. These units are
commonly referred to as dry-to-dry machines. The units use
cartridge-type filters; no distillation of the perc is performed
at a typical coin-op.
Cartridge filters being marketed for coin-ops include a
fluted paper cartridge with or without a core consisting of acti-
vated carbon, activated carbon and clay, or carbon. Activated
carbon adsorbs the dyes from the perc and the clay adsorbs non-
volatile residues. 6
Drycleaning Plants, Except Rugcleaning (SIC 7216 )
Establishments in this industry are often referred to as
commercial drycleaners, defined in the SIC manual as follows:
Plants primarily engaged in drycleaning or dyeing apparel
and household fabrics other than rugs (Industry 7217). Press
shops and agents for drycleaners are classified in Industry
7212. Establishments dyeing fabrics for the trade are
classified in Major Group 22.
These establishments include small neighborhood drycleaners
operating independently, franchised shops, and specialty cleaners
that clean leather and other fine goods. These cleaners typi-
cally process about 17,700 kg (39,000 lb) of clothes per year. 5
The range is from less than 9,000 kg to greater than 45,000 kg
(20,000 lb to greater than 100,000 lb) per year. Most of these
plants have 1 to 15 employees; typically a plant has 4 to 6
employees.
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Perc is the predominant drycleaning solvent used by this
group. Of all commercial drycleaners, 72 percent use perc, 24
percent use Stoddard solvent, and 4 percent use fluorocarbons.
The process consists of three basic steps: washing, extrac-
tion, and drying. In the washing step the clothes are washed in
one of two types of machines, characterized as transfer or dry-
to-dry machines. The transfer machines currently being manufac-
tured carry out the washing and extraction steps and then the
clothes are transferred to the dryer. The dry-to-dry machines
perform all of the steps: washing, extraction, and drying. To
date, the dry-to-dry machine has been used very little in commer-
cial perc plants because machine utilization is only half that of
the transfer machine, which allows simultaneous use of the washer
and dryer. Interest in the dry-to-dry machine is increasing,
however, because it can meet OSHA regulations more easily, and
requires less attention during the cleaning cycle than the trans-
fer type. Furthermore, the equipment manufacturers are increas-
ing their efforts to improve and sell this type. Presently,
about 25 percent of the commercial plants have dry-to-dry
machines .
The washing step may include one or two solvent baths,
although most commercial cleaners use only one. The use of a
two-bath system generally improves overall cleaning efficiency.
To aid in removing water-soluble soils, small amounts of deter-
gent (and sometimes water) are added to the solvent in the one-
bath system.
In the extraction step in both machines the solvent bath is
drained, then the clothes are spun at a high speed to wring out
excess solvent. Nost of the newer transfer machines are washer—
extractor types; thus the washing and extraction steps are the
same as in the dry-to-dry machines.
After the extraction step the procedure differs with the two
types of machines. With the transfer machines an operator trans-
fers clothes to the dryer-reclaimer. Current OSHA regulations
require that fresh air be blown across the operator when clothes
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are being transferred from the washer-extractor to the dryer.
This is accomplished by an exhaust fan, which pulls air into the
washer and dryer doors and away from the operator when the doors
are open.
All perc plants use a solvent-reclaiming dryer. Heated air
is blown over the clothes in a closed, recirculating loop to
vaporize the solvent, which is then recovered in a water-cooled
condenser. After a timed drying step (usually 15 to 20 minutes),
fresh air is blown over the clothes for approximately 5 minutes
to complete the drying cycle and aerate the clothes. During this
aeration portion of the drying cycle, the air stream and perc
vapors are frequently vented to the atmosphere. Approximately
35 percent of the perc plants have added carbon adsorbers to the
dryer exhausts to recover perc for economic reasons.
During the washing cycle, perc is passed through a filter
for removal of suspended matter and dyes. The filter may be
either a paper cartridge type or regenerative type. The paper
cartridge filter, usually containing some activated carbon for
removal of dyes, is re-used for several wash cycles and is drain-
ed before it is discarded. The regenerative filter is regener-
ated by ba kwashing the filter powder precoat and adding a new
precoat. The backwash contains diatomaceous earth, activated
carbon, suspended matter removed from the perc, and a consider-
able amount of perc that must be recovered. Perc recovery is
usually accomplished in a muck cooker, which is a distillation
unit with direct steam injection. Industry sources say the trend
is toward more extensive use of cartridge type filters.
Removal of nonvolatile residues, such as oils and fats, from
the perc is accomplished in a unit that distills the perc from
the impurities, which are discarded as still bottoms. Periodic
distillation of all or part of the solvent is necessary to pre-
vent buildup of these soluble impurities.
A typical commercial perc plant would have one washer-
extractor of 25- or 50-pound capacity, one or two reclaiming
dryers of equivalent size, a solvent filter with disposable paper
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cartridges, and a distillation unit. Figure 2-1 is a process
flow diagram of a typical commerical perc drycleaning plant.
Industrial Launderers (SIC 7218 )
The definition of SIC code 7218 for establishments within
this industry is as follows: 3
Establishments primarily engaged in supplying laundered or
drycleaned work uniforms; laundered wiping towels; safety
equipment (gloves, flame resistant clothing, etc.); dust
control items, such as treated mats or rugs, mops, dust tool
covers and clothes and other selected items to industrial or
commercial users. These items may belong to the industrial
launderers and be supplied to users on a rental basis, or
they may be the customer’s own goods. Establishments in-
cluded in this industry may or may not operate their own
laundry or drycleaning facilities.
Industrial launderers supply these textile goods to users in
commerce, industry, and government. Their annual volume of
business is currently about $1 billion. Work uniforms and execu-
tive shirts and slacks are usually drycleaned (with either Stod-
dard or perc solvent) because longer wear is achieved by dry-
cleaning than by laundering, and the aggressive action of the
solvents toward heavily greased items often produces superior re-
sults. 7 ’ 8 Laundering, with water and detergent, is nonetheless
indispensable in the removal of water-solubles such as perspira-
tion odors. Some launderers commonly use a dual-phase cleaning
process consisting of an initial water wash followed by a solvent
wash and rinse. 7 ’ 8
Some industrial launderers provide various dust control
items for use in the maintenance of machinery and its controls,
in prevention of soiling of finished products, and in dust con-
trol within working areas.
These items include:
o Wiping towels, which are a specially woven fabric, for
use in applications where no lint or residues are
tolerated.
o Chemically treated wiping clothes and mops, which do
not just “push dirt around” but actually pick it up.
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Figure 2-1. Commercial perc drycleaning plant flow diagram, with paper cartridge filter and carbon
ad so rbe r.
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Chemically treated rugs, which remove and retain shoe—
borne dust. These are typically used in such institu-
tions as hospitals, schools, and retail shops.
The dust control items may be either drycleaned or water-
washed, depending on how they are used. As with uniforms, these
dust control items may be either rented or owned by the customer.
Industrial launderers with drycleaning facilities constitute
about 42.5 percent of the total number of establishments. 5 About
27 percent of the total weight of uniforms, dust control items,
etc., is drycleaned with either perc or Stoddard solvent, the
split being roughly half and half. On the basis of number of
machines, however, the breakdown is 60 percent perc and 40 per-
cent Stoddard.
Although industrial drycleaning operations vary in number
and size of machines, a typical industrial system is a transfer
type, consisting of a 113 kg (250 lb) washer/extractor and a
matching dryer/reclaimer as described earlier. 5 Nultibath wash-
ing is common; that is; the items to be cleaned are subjected to
a water and detergent wash, a solvent wash, and a solvent rinse.
Solvent filtration is seldom used. 9 Suspended matter and nonvol-
atile resiaues are removed by distillation. The residue from
distillation is further treated in a muck cooker for removal of
solvent. A typical industrial drycleaning operation processes
470,000 kg (1,036,000 ib) of textile goods per year.
A typical industrial drycleaning operation is shown schema-
tically in Figure 2-2. The system consists of a washer/extrac-
tor, dryer, carbon adsorber, distillation unit, and muck cooker.
The plant handles 240,000 to 700,000 kg (600,000 to
1,500,000 ib) of clothes per year. The clothes (usually work
• uniforms) can be heavily soiled with caked dirt and various oils
and greases, including body oils. Shirts go through a water/
perc/perc (dual-phase) treatment, whereas pants are cleaned only
by two perc baths. A water bath is used on shirts to remove
water solubles, such as caked dirt and perspiration.
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4
Legend
CLEAN SOLVENT
TAN K
______ LIQUID LINE
GAS/VAPOR LINE
1 DISTILLATION UNIT
FEED TANK
2 DECANTER
3 CHEMICAL
4 DECANTER
5 DECANTER
CW CONDENSER WATER
LS LIVE STEAM
.1
SEPARATOR
H 20
MUCK
COOKI
LS
1
RESIDUE
DRY CLOTHES
WET CLOTHES
CLEAN CLOTHES
Figure 2-2. Flow diagram of industrial drycleaning operation.
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The perc washing and drying steps are similar to those in
commercial drycleaning plants. The washer and dryer vents are
connected to a carbon adsorber. Distillation of solvent is
carried out continuously in the still. The solvent distillation
rate is one bath per load. Solvent from the first perc bath is
distilled, with steam as the heat source. The oil that accumu-
lates in the still is pumped at the end of the day to the muck
cooker, where live steam is injected directly into the oil sol-
vent mixture (steam distillation) and indirect steam is the
source of heat. The distillation is continued until a sharp rise
in temperature of the outlet condenser cooling water is observed.
This occurs because the oil that is volatized once all the perc
has distilled over condenses at a much higher temperature. Since
the flow of cooling water to the condenser remains constant, the
outlet temperature of the cooling water rises. The condensed
solvent/water mixture is sent to a separator, from which reclaim-
ed solvent is sent to the still feed tank. A heavy black residue
in the still must be disposed of. The vents from all solvent
tanks, the still, and the muck cooker are connected by manifold
to a single water-cooled condenser, which in turn is vented to
the atmosphere.
Residual water (about 200 ppm) in the perc from the various
water separators is removed by passing the solvent solution
through a bed of salt (baker’s salt). To minimize solvent loss
in dual-phase operations, the washer/extractor and drains are
flushed with a minimal amount of water. This solvent is sepa-
rated in a two-stage process.
DEMOGRAPHY OF ESTABLISHNENTS IN THE COIN-OPERATED, COMMERCIAL,
AND INDUSTRIAL SECTORS
Data on the distribution of the drycleaning establishments
by State, EPA Region, and by nonattainment area were obtained
from County Business Patterns (CBP) 1976, an annual publication
of the Bureau of Census (BOC). 2 The detailed information is
given in the Appendix. The data compiled and reported include
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total number of establishments in each industry (SIC codes 7215,
7216, and 7218), in each county, arid in each state plus the Dis-
trict of Columbia. Data are also, given on independent cities
(such as Baltimore, Maryland) that do not lie within counties.
The independent cities within each state are listed in the World-
wide Geographical Location Codes . 1 °
Data from CBP show the total number of establishments in
each employment-size class, for each industry, and for each
county and state. The employment-size classes are as follows:
Employment-size
class
Number of
employees
1
lto4
2
5to9
3
lOtol9
4
20to49
5
50to99
6
100 to 249
7
250 to 499
8
500 to 999
9
1000 or more
As background for the pertinent demographic data, informa-
tion is given on the sources of data in CBP. This information
will aid the reader in understanding the limitations associated
with use of these data for estimating potential emissions and
identifying problem areas.
Data for the 1976 CBP are extracted from the BOC Standard
Statistical Establishment List. The Bureau updates these lists
annually on the basis of information obtained from the Internal
Revenue Service, the Social Security Administration, and the BOC
data files. Employment information on single-establishment
employers (or one-location employers) is obtained from the Social
Security 1976 first-quarter Form 941 Schedule A. Employment
information on multiestablishment (multilocation) employers is
extracted from 1975 and 1976 Annual Organization Surveys con-
ducted by the Bureau.
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Each legal entity (corporation, partnership, single proprie-
torship, etc.) having paid employees is required to file a sepa-
rate Employers’ Quarterly Federal Tax Return, Treasury Form 941,
identified by an employer identification number. For single-
location legal entities, each fourth quarter 941 report is count-
ed as an establishment. For multilocation legal entities, each
location is counted as one establishment if it is determined to
have been active as of December 15, 1976. The determination is
based on information from the 1976 Annual Company Organization
Survey.
Industry Classifications are based on the 1972 Edition of
the Standard Industrial Classification Nanual. 3 The classifica-
tion of an establishment is based on the principal product or
group of products produced or distributed, or on the principal
services rendered by the establishment. The term “principal”
indicates that the establishment derives 50 percent or more of
its revenue from the activities (or services) defined by the SIC
code. This is the so-called “50 percent rule.” Data are not
shown separately for any SIC having less than 50 employees in the
county, state, or United States. Data on such establishments are
reported, however, under the totals for the industry group. For
example, if the total employment in all commercial drycleaning
establishments (SIC 7216) in one county is less than 50, these
establishments are not reported under SIC 7216. They are re-
ported with the county totals for the major industry group 721.
Data from CBP on the coin-op, commercial, and industrial
launderers located in each EPA region and nonattainment area are
summarized in Tables 2-1, 2-2, and 2—3.
The totals reported for the coin-op sector (11,804) are far
below the estimated 40,000 establishments reported by Ward Gill,
President of the National Automatic Laundry and Cleaning Coun-
cil. 11 This difference is partly accounted for by the fact that
many of the coin-ops are owned by firms operating commercial
drycleaning establishments (SIC 7216) and industrial laundries
(SIC 7218). Since more than 50 percent of such a company’s
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TABLE 2-1. SUMMARY LIST: COIN-OPERATED LAUNDRIES
AND DRYCLEANERS IN THE UNITED STATES, 1976
Region
Total
coin-ops
Coin-ops
attainment
in
areas
Coin-ops
nonattainment
in
areas
I
558
128
430
II
1183
0
1183
III
1102
492
610
IV
2293
1618
675
V
2292
1444
1478
VI
1509
874
635
VII
697
558
139
VIII
361
281
80
I X
816
421
395
X
363
264
99
Total
11804
6080
5724
TABLE 2-2 SUMMARY LIST: COMMERCIAL
DRYCLEANERS IN THE UNITED STATES, 1976
Region
Total
commercials
Commercial
attainment
s in
areas
Commercials
nonattainment
in
areas
I
1092
72
1020
Ii
2920
0
2920
III
2115
501
1614
IV
3664
2255
1409
V
3680
1050
2630
V I
2292
1154
1138
VII
1000
631
369
VIII
579
274
305
IX
2049
590
1459
X
562
277
285
Total
19953
6804
13149
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TABLE 2-3. SUMMARY LIST: INDUSTRIAL LAUNDRIES
AND DRYCLEANERS IN THE UNITED STATES, 1976
Region
Total industrials
Industria
attainment
is in
areas
Industrials
nonattainment
in
areas
I
40
2
38
II
91
0
91
III
83
28
55
IV
182
97
85
V
192
67
125
VI
112
53
59
VII
53
40
13
VIII
14
8
6
IX
118
37
81
X
21
15
6
Total
906
347
559
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income is probably derived from the commercial or industrial
operations, they would be listed under those SIC codes. Also
many coin-ops are operated by an owner who has no employees. The
totals listed for the commercial and industrial sectors are more
likely to be accurate.
Classification of areas as nonattaininent with respect to
photochemical oxidants for each state are from a recent PEDC0
compilation based on information in recent issues of the Federal
Register.’ 2 Where the states reported nonattainment on the basis
of Air Quality Control Regions (AQCR), or parts thereof, within
the state, PEDC0 used the Federal Air Quality Control Regions
Manual’ 3 to obtain a list of counties within the AQCR(s). Where
counties lie only partially within an AQCR, the whole county is
assumed to be nonattainment. The numbers of establishments in
attainment areas were calculated as differences between the
counts for a state and for nonattainment areas within the state.
Drycleaning establishments are expected to be concentrated
in highly populated areas. The tables indicate that most dry-
cleaners are located in EPA Regions 2 through 6. Total percent-
ages for these regions are as follows: coin-ops, 76 percent;
commercials, 74 percent; and industrials, 73 percent. Percent-
ages of establishments located in nonattainment areas are as
follows: coin-ops, 48 percent; commercials, 66 percent; and
industrials, 62 percent.
POTENTIAL EMISSIONS
Perc emission factors express the amount of perc used to
clean a given weight of clothing. The smallest emission factor
indicates the most efficient plant. Emission factors may be
expressed in terms of individual emission sources or as overall
plant emissions. They are usually reported as kilograms of
solvent per 100 kilograms of clothing cleaned. When applied to
the solvent loss from an overall plant operation and reported as
weight of clothes cleaned per drum of solvent it is referred to
in the industry as “mileage.”
18
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The following sections concern the sources of perc emissions
and the associated emission factors. Total emissions based on
these emission factors are estimated for each state, for each EPA
region, and for each nonattainrnent and attainment area within
each state.
Sources of Perc Emissions and Emission Factors
A typical coin-operated establishment with drycleaning
facilities operates two 3.6 kg (8 ib) dry-to-dry perc drycleaning
units. A typical coin-op processes approximately 9,050 kg
(20,000 ib) of clothes per year. 5 Emissions of perc from the
typical coin-op include evaporation losses during aeration or
deodorization of the clothes and during filter disposal, and
miscellaneous losses, mostly by leakage.
A properly maintained and operated dry-to-dry coin-op unit
vents to the atmosphere only during the deodorization cycle.
Clothes contain 20 to 25 percent perc by weight after washing and
extraction. After drying, and before aeration, the clothes
contain approximately 3 to 6 percent perc by weight when the unit
is operated properly. When it is operated improperly, the clothes
can contain more than 3 to 6 percent perc and excessive perc
emissions will occur during the deodorization cycle.
Cartridge filters were originally introduced to the dry-
cleaning industry on the coin-op machines which use this type of
filter predominantly because it is a multicharge filter. Useful
life of a cartridge filter averages 60 to 65 loads of clothes for
a 3.6 kg (8 ib) capacity machine.’ 4 According to the CTG, car-
tridge filters are confined and contained, and thus inherently
hold the perc emissions to 1 kg of perc per 100 kg of clothes
cleaned (corresponding to 1 percent perc by weight).’ 5 Some
operators drain the filters in a double bucket arrangement. The
filter is placed in a perforated bucket and the perc draining
from the cartridge filter is collected in a second bucket under-
neath the perforated bucket. It is not known what percentage of
19
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coin-ops actually drain the filters in the double bucket or in
the filter housing.
Miscellaneous sources include fugitive emissions due to poor
maintenance of the drycleaning unit. Fugitive emissions include
both liquid and vapor losses. It is estimated that a 20 to
30 percent reduction of perc emissions can be accomplished with
good operation and maintenance of the coin-op drycleaning units. 3
Perc usage per pound of clothes drycleaned is higher for coin-ops
than for the commercial or industrial plants. The primary reason
for the higher emissions from the coin-operated unit is that five
loads of clothes in the 3.6-kg (8-ib) capacity unit equals the
weight of clothes processed in one load in a similar 18 kg (40-ib)
capacity unit in a commercial or industrial application. Since
each washing/drying cycle involves “fixed” solvent losses, the
larger unit emits less perc per pound of clothes cleaned.
Losses are exemplified by liquid leaks, vapor leaks, and
machine venting losses in solvent charging and discharging opera-
tions. Coin-operated units average as low as 1,500 lb of clothes
per drum of solvent and very rarely exceed 5,000 lb of clothes
per drum of solvent. For coin-op units, an emission factor of
35.1 kg perc per 100 kg clothes processed (2000 lb of clothes per
drum of solvent) is based on a range of values in an EPA report.’ 6
For commercial drycleaners using no carbon adsorber, the
aeration step is a major source of perc vapors to the atmosphere.
Other sources of perc emissions are transfer operations; evapora-
tion losses at the washer, dryer, and distillation unit; losses
from pumps, valves, flanges, seals, and water separators; and
losses from inefficient handling of solvent. In addition, signi-
ficant amounts of liquid perc are lost in disposal of distil-
lation and muck cooker residues and filter cartridges.
Plant emission factors derived from the surveys of Dallas
and Hamilton Counties (details in Section 4) include all plants
with and without carbon adsorbers, as shown in Table 2-4.
20
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TABLE 2-4. REPRESENTATIVE EMISSION
FACTORS FOR COMMERCIAL DRYCLEANERS
Employment-
size class
Emission factors,
kg perc/100 kg clothing
Dallas County
Hamilton County
Both
Counties
1-4 employees
5-9 employees
10-19 employees
2O employees
All
19.8 ( 31 )a
14 (35)
10.2 (9)
11.8 (2)
16.2 (77)
22.1 (46)
19.4 (17)
22.7 (8)
15.6 (1)
21.4 (72)
21.5 (77)
15.8 (52)
16.1 (17)
13.1 (3)
18.7 (149)
aNumbers in parentheses are the number of plants surveyed in each
employment-size class.
The emission factors above are arithmetic averages of values
from the Dallas and Hamilton County surveys. A linear regression
was performed on the data points; however, the correlation fac-
tors ranged from below 10 percent to about 50 percent for the
various employment-size classes. A correlation factor of at
least 80 percent would be necessary for assumption of a linear
fit of the data.
The weights of clothing cleaned in each employment-size
class, shown in Table 2-5, also result from the Dallas and Hamil-
ton County surveys. The numbers shown are arithmetic averages of
the reported amounts of clothing cleaned. These numbers are
considerably higher than the 17,700 kg/yr (39,021 lb/yr) of
clothing cleaned by a typical drycleaner, as reported following a
survey conducted by the International Fabricare Institute (IFI)
in 1975.16
The New Source Performance Standards (NSPS) Background
Document 5 developed a model plant for commercial drycleaners,
showing 28,175 kg/yr (62,115 lb/yr) of clothing cleaned. The
significantly higher results of PEDC0’s Dallas and Hamilton
County surveys conducted in 1979 reflect the expected increase in
demand for drycleariing services, as discussed in the NSPS Back-
ground Document. 5
21
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TABLE 2-5. REPRESENTATIVE WEIGHTS OF
CLOTHING CLEANED BY COMMERCIAL DRYCLEANERS
Employment-
size class
Clothing cleaned, kg/yr
Dallas
Hamilton
Both
Counties
1-4 employees
5-9 employees
10-19 employees
2O employees
All (Weighted
— average)
30,144 ( 31 )a
46,920 (35)
72,912 (9)
122,652 (2)
45,171 (77)
24,420 (46)
42,924 (17)
51,924 (8)
70,704 (1)
32,488 (72)
26,724 (77)
45,641 (52)
63,035 (17)
105,336 (3)
39,042 (149)
aThe numbers in parentheses are the number of plants surveyed in
each category.
Dry-to-dry machines are used exclusively by the coin-ops,
whereas they account for only 2.5 percent of drycleaning machines
in the commercial sector. Transfer units predominate also in the
industrial drycleaning plants, especially in the larger systems
of 113 kg (250 lb) capacity or more. Dry-to-dry machines are,
however, gaining acceptance in industrial operations because they
minimize exposure of workers to perc fumes.
The sources of emissions from industrial drycleaning systems
are as follows:
Improperly vented equipment
Solvent retained in distillation residues
Miscellaneous leaks of liquid and vapor caused by lack of
proper maintenance
Accidental losses and discharges of solvents
Excess emissions take place when point sources within the system
are not properly vented to a carbon adsorption system, as fol-
lows:
Perc-laden air vented during the 3- to 5-minute aeration
cycle
Vents from perc storage vessels
Vents from the washer/extractor
Ventilation hoods at pickup points such as the washer/
extractor door
22
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In tests conducted on behalf of EPA, losses from these point
sources totalled 7 kg per 100 kg of clothes (7 lb per 100 ib) in
the absence of a carbon adsorber.’ With a carbon adsorber, these
losses may be reduced to 0.3 kg per 100 kg of clothes.
Solvent retained in distillation residues is a potential
source of emissions when it is disposed of in open dumps in
containers that corrode readily or are easily punctured in han-
dling and transportation or in earth-moving operations at the
dump.
Most industrial drycleaners do not purify the solvent by
filtration, 9 but rather by distillation. Residue from the stills
contains suspended matter and non-volatile residues. In tests
conducted by IFI, the emissions from this source were estimated
at 1.6 kg perc per 100 kg of clothes (1.6 lb perc per 100 lb).’
Miscellaneous losses usually occur in leakage of liquid and
vapors. Liquids may leak because of defective gaskets on washing
machine doors and button traps or defective seals on pumps,
valves, and pipe fittings. Vapors may leak because of defective
gaskets on dampers used to isolate the air recirculated during
drying or because of tears, punctures, or other damage to air
ducts to and from the dryer. The IFI and EPA estimates of these
miscellaneous losses are 2 kg and 1 kg per 100 kg of clothes,
respectively.
These emission factors for industrial operations apply to
well-operated systems. The total emission factor for systems
without carbon adsorbers is 10.6 kg per 100 kg clothes, whereas
that for systems with carbon adsorbers is 3.9 kg per 100 kg
clothes. The latter value for well—operated systems has been
substantiated in source field measurements and reported for
others. 17 ’’ 8 ’’ 9 ’ 20 ’ 2 ’ At an industrial operation with a 136-kg
(300 ib) machine, tests conducted on behalf of EPA showed an
emission factor of 2.35 kg per 100 kg of clothes (2.35 lb per
100 lb).’ 7 ’ 21 At another industrial facility with two 113-kg
(250-ib) machines the emission factor was 4.5 kg per 100 kg
clothes.
23
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It is reported that 50 percent of all industrial drycleaning
systems are fitted with carbon adsorption control devices. 5 This
value yields a weighted emission factor of 7.25 kg per 100 kg of
clothes for well-operated systems, but it is not known how many
systems are well operated.
Data on four industrial drycleaning operations obtained in
the survey of Dallas County show that solvent consumption is
higher than 7.25 kg per 100 kg (7.25 lb per 100 ib). Solvent
loss in these plants averaged 15 kg per 100 kg of clothes (15 lb
per 100 ib).
Emission factors and assumptions used in calculating total
perc emissions are summarized in Table 2—6.
TABLE 2-6. SUMMARY OF EMISSION FACTORS AND WEIGHT
OF CLOTHING CLEANED PER ESTABLISHMENT.
Coin-Op
Commercial
Industrial
Emission factor, kg perc
100 kg clothes cleaned
per
All Plants
1-4 employees
5-9 éthployees
10-19 employees
2O employees
35.1
21.5
15.8
16.1
13.1
15
Clothes processed per
plant per year, kg
All Plants
1-4 employees
5-9 employees
10-19 employees
2O employees
9050
26,724
45,641
63,035
105,336
470,000
Fraction of plants with
drycleaning facilities
0.45
1.00
0.425
Fraction of plants using
perc
0.975
0.72
0 50
24
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Total Emissions
On the basis of the emission factors and representative
weights of clothing cleaned per establishment, total perc emis-
sions may be estimated. Table 2-7 summarizes these emissions by
EPA region and by nonattainment areas within each region.
The table shows that most perc emissions occur in the more
densely populated areas. EPA Regions 2 through 6 account for
74 percent of the perc emissions. Nonattaininent areas account
for 64 percent.
Nationwide total perc emissions based on the 1976 CBP fig-
ures for number of drycleaning establishments are 130,000 Mg
(143,000 tons). Sources in industry indicate that the perc
consumption is closer to 158,000 Mg (174,000 tons). A recent IFI
newsletter estimates that 15,000 coin-ops are using perc, almost
three times the number estimated by CBP. If it is assumed that
the number of coin-ops is twice that reported by CBP, the total
1976 perc emissions would be 146,000 Mg (161,000 tons). This
figure is within 10 percent of the reported consumption; the
assumption that the number of coin-op plants is twice that re-
ported in CBP is used in the following sections.
GROWTH PATTERNS
Patterns of growth in the three industry sectors to the year
1990 are discussed in this subsection and are summarized in
Table 2-8. These predicted growth patterns provide the basis for
projections of perc emissions over the same period.
Coin-Operated Laundry and Drycleaning
CBP reports the number of coin-operated laundries and dry-
cleaners with payrolls. It is a reasonable assumption that these
facilities with payrolls are the larger plants that operate
drycleaning units. CBP data for 1976 show 11,804 coin-ops. On
the assumptions of 23,608 coin-ops (twice the CEP value) and an
25
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TABLE 2-7. SUMMARY OF ESTIMATED 1976 PERC EMISSIONS FROM DRYCLEANERS (Mg)
I
II
III
IV
V
VI
VII
VIII
Ix
x
Total
777.6
1,648 7
1,535 7
3,195 7
4,072.5
2,103.1
971.4
503.0
1,137.3
505.9
16,450.9
599. 3
1,648.7
850. 1
940.8
2,060.0
885. 1
193.7
111. 5
550. 5
138. 0
7,977.7
5,508.7
13,817.7
11,102.3
18,763.4
18,797.8
11,563.2
4,895.3
2,870.7
10,307.4
2,688.6
100,315.1
5,163.3
13,817.7
8,525.6
7,513.4
13,808.1
6,113.1
1,941.9
1,535.0
7,430.1
1,371.2
67,219.4
599.4
1,363.3
1,243.5
2,726.6
2,876.4
1,677.8
794. 1
209. 7
1,767.8
314.6
13,573.2
569.4
1,363.3
824.0
1,273.6
1,872.7
883.9
194.8
89.9
1,213.5
89.9
8,375.0
Region
Perc emission from Perc emissions from Perc emissions from
coin-operated drycleaners commercial drycleaners industrial drycleaners
Total Nonattainment areas
Total
Nonattainment areas
Total
Nonattainment areas
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expected population growth rate of 0.9 percent, 5 the numbers of
coin-operated plants can be estimated for 1979, 1980, 1985, and
1990, as shown in Table 2-8.
TABLE 2-8. PREDICTED GROWTH PATTERNS
IN THE DRYCLEANING INDUSTRY TO 1980
(Number of establishments)
Year
Coin-ops
Commercial
Industrial
1976
23,608
19,953
906
1979
24,251
20,497
931
1980
24,469
20,681
939
1985
25,591
21,629
982
1990
26,763
22,620
1,027
At the 1979 World Educational Congress for Laundering and
Drycleaning, coin-op representatives advised fellow laundromat
operators to stay away from the drycleaning business. The major
reason cited for this was that the burning of perc fumes in
combustion air for laundromat dryers produces a green residue on
the burners, leading to reductions in dryer efficiency and in-
creases in maintenance cost.
At present, 97.5 percent of the coin-op drycleaning opera-
tions use perc as the drycleaning solvent. Most industry sources
agree that perc will continue to be the predominant solvent for
coin-ops, although classification of perc as a carcinogen or
hazardous pollutant may reverse the role of perc in the entire
drycleaning industry. The use of closed systems with perc as a
drycleaning solvent would be a viable alternative if this occurs,
or other solvents believed to be nonphotochemically reactive,
such as Freon (F-113), could be used in place of perc. There is
some indication, however, that fluorocarbons such as F-113 may
cause depletion of the upper atmospheric ozone layer.
Growth Patterns for Commercial Drycleaners
The number of commercial drycleaning establishments declined
from 1967 through 1976, a period in which synthetic, washable
fabrics were becoming more popular. Also, the demand for dry-
cleaning.services decreases during times of adverse economic
27
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conditions, as occurred in 1974 and 1975. During that period the
trend was toward fewer, larger establishments with larger ma-
chines.
In the past several years clothing stylists have begun to
use more natural fabrics, a change that is expected to increase
the demand for drycleaning in both the commercial and coin-oper-
ated sectors. 5 There is no evidence to suggest whether consumers
would switch from commercial drycleaning to the less expensive
coin-operated units if a recession should occur. Industry sour-
ces indicate that switching is unlikely, and that demand in both
sectors should increase gradually during the next 5 to 10 years.
This increase in demand is expected to be about equal to popula-
tion growth or about 0.9 percent per year according to recent
EPA-sponsored studies. 5
With the number of establishments in 1976 as the base num-
ber, application of a growth factor of 0.9 percent per year
yields the increase in number of establishments shown in Table
2—8.
Growth Patterns in the Industrial Sector
Recent trends in the industrial sector indicate a move
toward fewer but larger plants. The total number of establish-
ments has decreased between 1967 and l976. Although this sector
is also affected by general economic trends, annual growth rates
(both negative and positive) in number of establishments have
been of the order of few percentage points. Since no general
economic downturn took place between 1976 and the present time, a
positive growth during that period may be assumed. Industry
sources indicate that growth in weight of articles cleaned (both
laundry and drycleaning) by the industrial sector usually paral-
lels the growth in population. 8 ’ 9 Again, the EPA population
growth rate of 0.9 percenL per year is used to predict the growth
of industrial drycleaning sources to 1990.
A large growth in perc drycleaning at the expense of water
and detergent-based laundering has been anticipated, mostly
28
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because of the enactment of water pollution regulations affecting
the use of detergents. 8 In addition, the rising sewerage rates
levied by municipalities on the basis of total water used en-
hanced the prospects for use of perc cleaning in lieu of water
washing of some articles. The anticipated switch to perc has
been limited, however, by current OSHA regulations limiting
worker exposure to a total weighted average concentration of
100 ppm perc in the work environment and by pending EPA regula-
tion of perc emissions from new and existing sources. Addi-
tionally, EPA has determined that perc may be a carcinogen. If
this is confirmed, the use of perc may be restricted. All these
factors tend to create uncertainties in predicting future use.
No new sources are expected to use petroleum solvents because
of their higher cost and potential fire hazard. Existing perc
systems are expected to be replaced by similar, but perhaps
larger, perc-based systems. Therefore, the current estimated
level of perc usage for 50 percent of all drycleaning is expected
to hold throughout the period to 1990.
Perc Emission Projections
Current annual consumption of perc is reported at 158,000 Mg
(174,000 tons). Estimated 1976 perc emissions, based on the
number of drycleaning establishments given by CBP and an assump-
tion that the number of coin-ops is twice that reported, are
146,000 Mg (161,000 tons); this figure is used in the emission
projections.
Until application of RACT, increases in perc emissions will
match the rate of increase of number of establishments, or 0.9
percent per year. Perc emissions should then decrease with the
application of RACT to the perc drycleaning industry. The main-
tenance part of the proposed regulation is expected to become
effective at the end of 1980. Full compliance (application of
carbon adsorption or equivalent technology) should be achieved by
the beginning of 1982. When application of RACT is complete,
perc emissions will increase with population growth.
29
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The CTG and proposed standards background documents, give
uncontrolled and controlled emission factors for the three indus-
try sectors. This report indicates that the uncontrolled emis-
sion factors are considerably higher, and hence that the con-
trolled emission factors will also be higher. Table 2—9 presents
the emissions factors from References 1 and 5 and those predicted
in this study. The emission factors reported in these references
were obtained from three carefully controlled emission tests. It
is our opinion that emissions from actual operations will not be
so low; however, the same percentage of emission reduction in
each sector is probably achievable with application of RACT.
TABLE 2-9. PERC EMISSION FACTORS BEFORE AND AFTER
APPLICATION OF RACT, kg/lOO kg OF CLOTHES
CTG emission factorsa,b PEOCo emission factors
Uncontrolled Controlled Uncontrolled ControlledC
Coin-op
Commerical
Industrial
20
12
12
15
5
5
35.1
18.7
15
26.3
7.8
6.2
aReference. 1, pp. 5-2, 5-3.
bReference 5, p. 6-7.
ccontrolled emission factors were obtained by multiplying PEDC0’s
uncontrolled emission factors by percentage reduction predicted
by EPA for each industry sector.
Projections of controlled perc emissions for 1980, 1985, and
1990 are presented in Table 2—10.
TABLE 2.10. PROJECTIONS OF CONTROLLED PERC EMiSSIONS (Mg)
Year
C1G
PEDCO
1976
146,800
146,800
1980
152,200
152,200
1985
50,500
80,200
1990
52,900
83,900
30
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SECTION 3
CONTROL TECH1 4OLOGY AND FACTORS AFFECTING ENFORCEMENT
In December 1978, the EPA Office of Air Quality Planning and
Standards issued a CTG that specified means of controlling perc
emissions from drycleaning systems in the coin-op 1 commercial,
and industrial sectors. Regulations based on reasonably avail-
able control technology are currently being formulated. This
section briefly describes RACT and the factors affecting enforce-
ment.
SUMMARY OF REGULATIONS
On the basis of the control technology specified in the CTG
document, 1 regulations affecting existing sources of perc emis-
sions from the three sectors of concern are to be issued shortly.
The following paragraphs summarize the expected regulations.
The regulations apply to all perc drycleaning systems in the
coin-operated, commercial, and industrial sectors. The owner or
operator of a drycleaning facility must accomplish the following:
Vent the entire dryer exhaust through a properly func-
tioning carbon adsorption system or equally effective
control device;
Emit no more than 100 ppm of volatile organic compounds
from the dryer control device before dilution;
Immediately repair all components found to be leaking
liquid volatile organic compounds;
Cook or treat all diatomaceous earth filters so that
the residue contains 25 kg or less of volatile organic
compounds per 100 kg of wet waste material;
Reduce the volatile organic compounds from all solvent
stills to 60 kg or less per 100 kg of wet waste mate-
rial;
31
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Drain all filtration cartridges, in the filter housing,
for at least 24 hours before discarding the cartridges;
and
When possible, dry all drained cartridges without
emitting volatile organic compounds to the atmosphere.
For systems where solvent purification is not done by dis-
tillation, muck cooking, or filtration, the owner/operator must
restrict wastes losses resulting from solvent purification to
1 kg per 100 kg clothes processed (1 lb per 100 ib). Demon-
stration of these loss limits is also required.
The following drycleaning systems will be exempted from the
provisions pertaining to carbon adsorption and the associated
100 ppm emission limit:
Coin-operated drycleaning systems.
Other systems where space limitations prevent the installa-
tion of a carbon adsorber and/or systems where steam re-
quired for desorption of the carbon bed is not available.
Compliance with regulations is expected to be monitored as
follows:
Compliance with items pertaining to the installation of a
carbon adsorber and draining and drying of filter cartridges
will be determined by visual inspection.
Compliance with items pertaining to repair of system compo-
nents found to be leaking will be determined by visual in-
spection. Specifically the following components are includ-
ed in this item covering liquid leaks:
Hose connections, couplings, and valves.
Machine door gaskets and seatings.
Filter head gaskets and seatings.
Pumps.
Base tanks and storage containers.
Water separators.
Filter sludge recovery.
Distillation unit.
Diverter valves.
Saturated lint from lint basket.
Cartridge filters.
32
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Compliance with the 100 ppm emission standard will be deter-
mined by:
Tests methods outlined in EPA Guideline Series docu-
ment, “Measurement of Volatile Organic Compounds,” EPA
450/2_78_041.22
Determination of the proper installation, operation,
and maintenance of equipment that has been demonstrated
to be adequate for meeting the specified emission
limit.
Compliance with items pertaining to limits on perc contents
of residues from distillation and muck cooking operations will be
determined by the American National Standards Institute standard
procedure for determination of “Dilution of Gasoline Engine
Crankcase Oils.”
REASONABLY AVAILABLE CONTROL TECH1 OL0GY (RACT) FOR
PERCHLOROETHYLENE DRYCLEANING SYSTEMS
The regulations just described are based on control tech-
niques specified in the CTG document.’ Briefly these techniques
consist of (1) the use of activated carbon adsorption for control
of emissions from air streams containing perc vapor and (2) the
implementation of good housekeeping and equipment maintenance
practices to control fugitive emissions, liquid leaks, and mis-
cellaneous losses. Coin-operated systems are exempt from the use
of activated carbon adsorption because such facilities may lack
steam to desorb the carbon bed and/or lack the space needed for
installation of an adsorption system.
Activated carbon adsorption has been found effective in
controlling typical vapor emissions from point sources in commer-
cial and industrial drycleaning systems. In EPA tests, perc
concentrations at the carbon bed inlet ranged from 540 to 6500
ppm. 19 ’ 20 ’ 21 Removal efficiencies were usually 95 percent or
more, with outlet concentrations usually below 100 ppm. The
latter is an emission requirement specified by regulations.
Activated carbon suitable for adsorption of organic vapors
is obtained from carbonization of organic materials (such as
33
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lignite, peat, and wood) and subsequent activation. The carbon-
ization process produces a spongelike structure with a large
internal surface area (500 to 1000 m 2 /g). Size of the pores
within the carbon structure are on the order of the size of the
molecules to be adsorbed. Size of the pores is not uniform,
however, and the pores are thought to consist of voids between
crystallites of carbon formed during carbonization. Activation
of the carbonized material consists of subjecting it to steam
and/or air at high temperatures to effect oxidation and to re-
moval strongly adsorbed hydrocarbons. This exposes the surface
area between the crystallites, which exert an attractive force on
the species of interest with which they are brought into con-
tact. 23
Beds of activated carbon suitable for use in adsorption of
perchioroethylene vapors from drycleaning operations are designed
according to the following criteria: 24
Space velocities of the order of 100 reciprocal minute.
Space velocity is defined as the ratio of volumetric
flow of treated gas to volume of bed.
A ratio of volumetric flow rate to bed cross-sectional
area of about 328 m 3 per minute per m 2 of cross sec-
tional area (100 ft 3 per minute per ft 2 ).
A bed working capacity of about 20 percent. That is
the weight of perchioroethylene adsorbed (and also
amenable to desorption) as a percentage of the total
weight of activated carbon.
Carbon bed depths range from 0.23 to 0.81 m (9 to 32 in.).
The volumetric gas flow vented to the carbon bed during aeration
is usually about 0.25 dry standard cubic meter per minute per kg
of clothes dried (4 dscfm per ib). Temperatures of the bed inlet
and outlet gas are about 43°C and 24°C (110°F and 75°F) respec-
tively. Moisture contents are usually near 1 percent.’ 9 ’ 20 ’ 2 ’
The adsorbed perc may be desorbed with steam at the rate of
about 4 kg steam per kg of perc to be desorbed.
All sources of vapor emissions may be vented to carbon
adsorption systems:
34
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washer/extracter vents
solvent tank vents
floor pickup points
vents from distillation units and muck cookers
water separator vents
air from the deodorization (or aeration) step.
The regulations require good housekeeping and maintenance
practices in all three sectors of the perc dry cleaning industry.
Two types of perc losses are defined.’ The first pertains to
“point” losses and the second to “fugitive” losses. These losses
may be either in vapor or liquid form.
Leakage of liquid is relatively easy to detect by visual
inspection of piping, fittings, and solvent storage vessels.
Leakage of vapor is more difficult to detect but can be detected
by smell (at 50 to 200 ppm), by use of soap solution on piping
ductwork and fittings, or by use of an organic vapor detector.
The most common causes of solvent loss or emission, both in
liquid and vapor form, are given below.’’ 25 Required inspection
and/or maintenance procedures are discussed briefly.
Hose onnections, unions, couplings and valves : These
should be inspected at least monthly. They should be
tightened, repaired or replaced if leaks develop.
These are mainly sources of liquid leaks.
Nachine door gaskets and seating : During the wash
cycle an ill-fitting or damaged door gasket will cause
solvent to leak. This could occur if the gasket is old
and needs replacement. An old gasket usually develops
cracks and/or feels hard. Faulty door gaskets may be
sources of liquid and vapor leaks.
Solvent filter gaskets and seatings : With frequent
assembly and disassembly of solvent filters, the gaskets
become damaged. This is especially true of paper
cartridge filters, which are replaced periodically.
Seals on button traps require similar maintenance.
These are mainly sources of liquid leaks.
Pumps : Pump seals should be inspected and properly
maintained to prevent liquid leaks.
35
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Base tanks and solvent storage tanks : These should be
properly vented to water-cooled condensers or prefer-
ably to carbon adsorbers to prevent vapor leaks.
Corrosion of tanks and fittings may lead to liquid
leaks.
Water separators : Solvent loss in a water separator
may occur in the water layer as a result of a lint—
clogged vent or corrosion in the line leading to the
solvent tank. Liquid leaks and solvent loss may occur.
Filter sludge recovery : The muck should be cooked down
in such a way as to maximize perc recovery. The perc
content should be determined according to the standard
ANSI method for determination of dilution of gasoline
engine crackcase 011.26
Distillation unit : The distillation unit should be
properly operated and vented to a condenser or an
activated carbon adsorption unit to prevent vapor
leaks. The unit must be operated and maintained in
such a way as to prevent liquid leaks and solvent loss.
Diverter valves : These valves must be inspected and
maintained to prevent liquid leaks.
Saturated lint from lint basket : All lint traps should
be inspected and cleaned out daily.
Cartridge filters : Spent cartridge filters should be
drained for 24 hours before disposal. They can be a
source of liquid solvent loss.
Lint accumulation at various points in the drycleaning
system may cause undue loss of perc in vapor form. A clogged
lint bag (used in removing lint from recirculating air during
drying) reduces the air flow and the amount of solvent recovered.
Lint should be removed from the bags twice daily, and the bags
should be drycleaned twice monthly to remove grease buildup,
which tends to mat the lint and cause undue resistance to air
flow. 8
Lint buildup on condenser and heating units reduces the
cooling and heating capacities of these units and thus reduces
solvent recovery during the drying phase. Consequently, more
perc is vented during aeration, and more is retained in the
clothes. Condenser and heating units should be inspected, and
lint buildup removed at least once every 6 months. Accumulation
of lint at air inlet and outlet valves (dampers), may prevent
36
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them from seating properly during the drying cycle and thus cause
vapor losses.
FACTORS AFFECTING ENFORCEMENT OF REGULATIONS
The CTG’ that specifies RACT for control of emissions from
perc dry cleaning systems specifically recommends the use of
activated carbon adsorption for control of perc in the dryer
exhaust during the aeration cycle. The subsequently promulgated
regulations have additionally allowed the use of “equally effec-
tive control devices.” Although the CTG does not describe equal-
ly effective control devices, some are mentioned here as an aid
to EPA in investigations of the effectiveness of such devices.
These systems utilize refrigeration to temperatures as low as
—29°C (-20°F) as a means of condensing perc from the air stream
recirculated during the aeration phase of the cleaning cycle.
The manufacturers/distributors of these refrigeration systems are
Spencer America Corporation and Kleen-Ri.te, Inc., both of St.
Louis, Missouri.
It is emphasized that, unlike carbon adsorption systems,
these devices recirculate the air during aeration in refrigera-
tion systems. In adsorption systems fresh air is blown through
the clothes (once-through). This apparently renders carbon
adsorption technically more versatile than refrigeration, espe-
cially in transfer systems, because the adsorber can be used in
recovery of perc from vents, distillation units, floor pickup
points, etc. Conceptually, refrigeration systems may be used in
these extended applications, but the technical and economic
feasibility is yet to be determined.
Perc concentrations in the air vented through well operated
activated carbon systems during aeration have been consistently
much lower than 100 ppm.’ 7 ’’ 8 ’ 19 ’ 20 ’ 21 The regulations specify a
100 ppm limit because enforcement officials regard it as ample
indication of breakthrough. Although accurate methods are avail-
able for determination of perc at the specified concentration,
37
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there are apparently no relatively inexpensive devices for deter-
mination of continuous compliance with the standard. EPA is
currently involved in development of a reference method for
determination of perc in the concentration ranges of interest.
The availability and cost of such a device will strongly affect
future compliance monitoring activities. Although the currently
available gas chromatographic methods are technically adequate
for determination of initial and continuous compliance, the costs
of operating such a monitoring device are burdensome to industri-
al and commercial establishments. Furthermore, such establish-
ments are not likely to employ persons capable of calibrating,
operating, and maintaining such detection devices. For purposes
of enforcement, it may be feasible to establish relatively simple
“indicators” with which enforcement officials can determine
whether the adsorbers are effective in removing perc vapors.
Such indicators would be, for example, observation of the weight
(or volume) of perc obtained after each desorption of the carbon
bed. Such an observation, however, is an indicator only when all
key maintenance and housekeeping practices are followed. For
example, the volume of perc obtained after each desorption is not
a true indicator when the air inlet and outlet dampers do not
seat properly because of defective gaskets or lint accumulation.
The regulations call for the immediate repair of all system
components found to be leaking liquid perc. Compliance with this
stipulation is generally easier for industrial sources than for
commercial ones. The larger industrial establishments usually
employ personnel who are trained in the maintenance of the dry-
cleaning system. Commercial drycleaning systems are less likely
to employ such personnel, and because their employees are usually
involved chiefly in system operation they are more likely to
emphasize “production” rather than maintenance.
The allowable perc contents in residues from muck cooking
and distillation operations are 25 and 60 kg perc per 100 kg of
wet waste material, respectively. Although relatively few data
are available on the perc separation and recovery capabilities of
38
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muck cookers and distillation units, measurements taken on behalf
of EPA indicate that well operated systems can achieve much lower
perc contents in the residues from these units. Perc contents of
the order of a few percent are reported. 17
The regulations do not comment on residual perc in the
carbon that is removed from a carbon adsorber and replaced.
Activated carbon vendors all agree that the actual adsorption
capacity of the carbon is 60 percent by weight; however, only
20 percent by weight is the useful capacity (that which can be
desorbed). The implication, therefore, is that the carbon will
contain 40 percent by weight, or 40 kg perc per 100 kg of carbon,
at the time of disposal. It is estimated that the average ser-
vice life of activated carbon is 3 to 5 years. It may be neces-
sary to require disposal of the carbon in sealed containers to
prevent release of perc to the atmosphere after disposal.
The regulations call for draining of all filtration car-
tridges in their housing for at least 24 hours to minimize the
perc contents. Where multi-element solvent filtration systems
are available (as is likely in commercial establishments) drain-
ing of spent cartridges for 24 hours is feasible. Coin-operated
filtration systems, however, are usually single—element systems,
and the 24-hour drainage requirement may thus be a hardship. A
double-bucket device with a lid may serve for drainage of the
filter cartridges without unacceptable perc emissions.
Further removal of perc from the cartridges may be effected
by drying with hot air in an oven-type device that is marketed
for this purpose. It is also feasible to use the tumbler of a
dryer to dry the cartridges by holding the wheel stationary. The
regulations do not specifically require the drying of cartridges,
which is left to the discretion of the operator.
Difficulties for enforcement officials could arise from the
regulations pertaining to (1) use of a properly functioning
carbon adsorber, (2) limit of emissions from the dryer control
device to 100 ppm, (3) repair of all components found leaking
liquid, and (4) draining and drying of filtration cartridges.
39
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Difficulties with the first two items are the lack of a rela-
tively inexpensive continuous monitor of perc in the concentra-
tion range of 10 to 200 ppm and the lack of a program for demon-
stration of the adequency of control equipment. Difficulties
with the latter two involve the time required for enforcement
officials to identify leaky components and to determine that
filtration cartridges are drained for 24 hours. Such enforcement
actions may be impractical when the total number of sources is
between 33,000 and 36,000 nationwide.
The difficulties mentioned above may be circumvented by
modifying the regulations to include a specified rate of solvent
consumption (called a mileage standard). For industrial and
commercial establishments the standards for rate of solvent
consumption would be based on data obtained from well-operated
systems with carbon adsorbers. Such rates, as given in the CTG, 1
are expected to be in the range of 2 to 5 kg perc per 100 kg
clothes; the PEDC0 study, however indicates that emission rates
from the well-operated plant may be as high as 8 kg perc per
100 kg clothes. For coin-operated establishments the performance
standard would be in terms of kilograms of perc consumed in every
10 (or 100) cleaning cycles that the machine performs.
For commercial and industrial establishments the reporting
requirements with the “mileage standard would be a quarterly (or
monthly) submittal of data on total weight of clothes cleaned and
amount of perc consumed. For coin-operated systems the require-
ments would be the same except that total nunibex f cycles (based
on total receipts) would be reported instead of weight of cloth-
ing. The reported data on solvent consumption could be verified
by sales information from solvent manufacturers and distributors.
Data on weight of clothing drycleaned could be verified by esti-
mates of number of loads run in machines of given capacity.
Although such estimates may not be accurate, approximate agree-
ment with the reported value of clothes processed would enhance
the credibility of the latter.
40
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Officials of the South Coast Air Quality Management District
in Los Angeles indicate a preference for regulations based on
mileage criteria. The California Air Resources Board, however,
has stated that such a regulation is unenforceable because an
establishment’s records cannot legally be used in citing the
establishment for a violation. The legality of such use of
records to enforce mileage criteria should be investigated.
The regulation exempts from installing carbon adsorbers or
equivalent technology any facilities that are coin-operated, have
space limitations, or lack the steam capacity for desorption of
the carbon adsorber. An alternative approach might be to cate-
gorize drycleaning facilities into ranges of annual perc consump-
tion. All drycleaners with annual consumption below a certain
level would be exempt from installing a carbon adsorber. A
similar approach has been used in California in enforcement of
the petroleum solvent regulation. The advantage of such an
approach is that it concentrates on the larger perc emission
sources having substantial impact on the overall perc emissions
and exempts the truly small sources, with probably insignificant
perc emissions, for which installation of the required controls
may be ecohomically prohibitive.
41
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SECTION 4
METHODS OF IDENTIFYING EMISSION
SOURCES AND QUANTIFYING EMISSIONS
SOURCES OF INFORNATION
After investigating a variety of data sources for demograph-
ic information on coin-operated, commercial, and industrial
drycleaners, we determined that a Bureau of Census (CBP) report 2
and the yellow pages of the telephone directory provided the most
useful and complete information. Trade associations, government
agencies, and professional business offices were also contacted.
All drycleaners are required to report annually their number
of employees. The CBP report presents, for each county, the
total number of people employed in a given industry (by SIC
code), the total payroll for the quarter and the year, and the
number of establishments in various employment size catagories.
Because the same information is available for every county in the
United States, the report can be used to indicate the nationwide
distribution of coin-operated, commercial, and industrial dry-
cleaners.
The CBP report does not provide names of drycleaning estab-
lishments. We therefore contacted the Texas Laundry and Dry
Cleaning Association, which receives information from the Inter-
national Fabricare Institute, a trade association for dryclean—
ers, which periodically provides each state association with a
list of drycleaners in that state. The IFI list, however, is not
available for public use. Moreover, because of the rapid turn-
over in ownership of drycleaning establishments, it is not possi-
ble for either the state or international association to maintain
an up-to-date list.
42
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The most complete lists of drycleaners were obtained from
two companies, R. L. Polk and National Business Lists, who
specialize in publishing lists of businesses. Both companies use
the yellow pages in compiling their lists, in which businesses
are classified by SIC codes. National Business Lists states that
they delete repetitive listings from their lists, and thus help
the user to avoid duplication in contacting the businesses. A
principal disadvantage in using either the yellow pages or busi-
ness lists derived from them is that not all drycleaners have
telephones, particularly coin-operated cleaners, and not all dry-
cleaners who have a telephone list their business in the yellow
pages.
SURVEYS OF DALLAS AND HANILTON COUNTIES
As the basis for a nationwide projection for the drycleaning
industry, we studied in detail two metropolitan areas: Dallas
County, Texas, and Hamilton County, Ohio. Names, addresses, and
telephone numbers of drycleaners were obtained from the yellow
pages.
Coin-operated cleaners are listed under “Cleaners-Self
Service”, and tlLaundriesself Service.” Commercial drycleaners
generally appear under the heading “Cleaners.” Duplicate list-
ings for some establishments are found under “Hat Cleaners,”
“Leather Cleaning,” “Fur Cleaning,” or “Laundries.” Industrial
cleaners are listed under “Uniform Rental,” or occasionally
“Tuxedo Rental.”
PEDC0 investigators telephoned the cleaners in Dallas and
Hamilton Counties listed under each of these headings to ask
whether they would supply information for the survey of dryclean-
ers. Figure 4-1 illustrates the data sheet used in contacting
each drycleaner by telephone. From the information on the data
sheet, one can determine perc consumption per quantity of clothes
cleaned (or mileage rates). In assessing preliminary responses
to the survey, we decided to eliminate questions dealing with
sales and payroll figures because these questions generally
43
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1ame: ________________________________ Telephone No. ________________
Mdress: ______________________________ Manager/owner: —
County: ______________________________ SIC: __________________________
Type of operation: ______Commercial ______Coin-operated Industrial
Solvent used:
Qty. of solvent used: _______gallons/day cIrums/rronth
Solvent recovery equipment: ________yes no
If yes, type
No. of machines:
Do you plan to increase or decrease the number of machines at your
location?
Capacity of machines: ___________________________________________
Pounds of clothes processed (per batch or day) _______________________
Process clothes onsite? ___________________________________________
No. of batches per day:
No. of employees: —
Operating schedule: ___________days/week __________weeks/year
Sales: _______________________
Payroll:
Comments:
Figure 4-1. Drycleaning Industry Data Sheet.
44
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evoked a negative reaction. Drycleaners using perc in machines
equipped with carbon adsorbers were asked additional questions.
The survey of 129 coin-operated laundries and drycleaners
showed tha 31 do not have drycleaning equipment. Of the 98
installations with drycleaning equipment, 17 percent reported use
of perc ana 54 percent did not know or report the solvent used.
These establishments are often attended by persons who are not
involved in purchasing solvent or maintaining the machines; in
some cases a customer answered the telephone and reported that no
attendant was present. Among the drycleaners called, 2 percent
use freon as solvent, 8 percent were out of business, 5 percent
elected not to answer questions over the telephone, and 14 per-
cent did not answer their telephone on several occasions; it is
assumed the latter are unattended. With respect to enforcement,
one should note also that it is generally not possible to main-
tain records of the weight of clothing drycleaned in a given time
period at a coin-operated facility.
PEDC0 attempted to contact 581 commercial drycleaners listed
in the yellow pages. Among these, 5 percent were no longer in
business and another 17 percent refused to answer the survey
questions bver the telephone. Approximately 21 percent of these
commercial drycleaners are pickup stations for other commercial
drycleaning plants; the survey questions do not apply to such
operations. Eighteen percent of the commercial drycleaners
listed in the yellow pages used solvents other than perc. The
remaining 39 percent use perc, and of these, approximately 30
percent indicated that they are using a carbon adsorber; another
4 percent said they plan to add a carbon adsorber.
The survey of industrial dr ycleaners showed a higher usage
of carbon adsorbers. Of 16 industrial drycleaners contacted, 56
percent use perc and 67 percent of those using perc have a carbon
adsorber. Of the remaining 44 percent of the industrial dry-
cleaners surveyed, 31 percent use solvents other than perc (naph-
tha) and 13 percent dealing primarily in laundry services send
their drycleaning to a commercial drycleaner.
45
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Twenty-six commercial drycleaners in Dallas County using a
carbon adsorber were asked additional questions regarding the
life of the carbon bed. Results of these inquiries are presented
in Table 4 -1. Five of the owners reported operating their ad-
sorbers from 3 to 18 years without changing the carbon. Four
owners reported changing the carbon every 1, 3, 5, and 10 years.
Twelve owners reported that their adsorbers are less than 3 years
old and the carbon has not been changed. Five did not give the
age of their adsorbers nor indicate how often they change the
carbon. None of the owners had tested their adsorbers to deter-
mine outlet concentrations of perc.
In addition to contacting drycleaners by telephone, we
visited several commercial plants to verify data and gain know-
ledge of the drycleaning process.
RESULTS OF SURVEY
Results of the telephone survey of the commercial sector are
given in Tables 4-2 through 4-9, categorized in terms of four
employment size classifications. An arithmetic average of the
emission rate (kg of perc consumed per 100 kg of clothes cleaned)
was calculated for each employee classification. These figures
were used to calculate industry emissions from the commercial
drycleaning sector, as given in Section 2.
The survey data, plotted for each employment size category
in Figures 4-2 through 4-5 show a wide scatter of the data points.
In least-squares regression analysis of each classification,
correlation factors ranged from 9 to 50 percent. Because of the
poor correlation obtained for a linear fit, arithmetric averages
of the emission factors and the clothes processed are reported.
The arithmetic average equally weights each data point obtained
in the survey.
46
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TABLE 4-1. SURVEY OF DALLAS COUNTY COMMERCIAL
DRYCLEANERS USING CARBON ADSORBERS
Manufacturer
Age
of
Frequency
of carbon
Desorpti on
schedule,
times
Basis
of
of adsorber
adsorber, yr.
replacement
per week
desorption
schedule
Hoyt <1 Never Daily Amount of perc recovered
Hoyt NAa Never 2-3 Amount of clothes
processed
Vic 3 Never Daily Amount of perc recovered
NAa 10 Once per Daily NAa
year
Hoyt <1 Never 3 Detection of perc by odor
Hoyt <3 Never 2-3 Fogginess of filter gauge
Vic >5 After 3 NAa NAa
more years
Hoyt <1 Never 2 Amount of clothes
processed
Hoyt 5 Never Daily Manufacturer’s
recommendation
Hoyt NA 3 Never Daily Manufacturer’s
recommendati on
Hoyt >5 After 5 Daily Manufacturer’s
years recommendation
Hoyt 4 Never Daily Manufacturer’s
recommendati on
Hoyt <1 Never NAa NA 3
Hoyt <1 Never 1 Detection of perc odor
Hoyt 1.5 Never 3 Amount of perc recovered
a
Hoyt 1.5 Never 3 NA
Hoyt NAa NA 3 NA 3 NA 3
Hoyt 1-2 Never 2-3 Amount of clothes
processed
(conti nued)
47
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TABLE 4-1. (continued)
Desorpt ion
Frequency
schedule,
Manufacturer
Age of
of carbon
times
Basis of
of adsorber
adsorber,
yr.
replacement
per week
desorption schedule
Hoyt
8
Never
3-5
Amount of clothes
processed
Vic
1.5
Never
Daily
NA 3
Vic
1.8
Never
3
Amount of clothes
processed
Hoyt
0.5
Never
Daily
Amount of clothes
processed
Vic
1.5
After
10 years
b
Detection of perc odor
Vic
2
Never
Daily
Detection of perc odor
Hoyt
NAa
NA 3
NA 3
NA 3
Hoyt
>30
NA 3
NA 3 —
NA 3
aNA - not available.
bReported desorption once per month but stated that it should be done every
2 weeks.
48
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TABLE 4-2. COMMERCIAL DRYCLEANERS
WiTH 1 TO 4 EMPLOYEES
Number
employe
of
es
Clothes processed per month
Perc consumed per month
kg
lb
kg
lb
Dallas County
1 1588 3500 612 1350
1 943 2080 319 703
2 2071 4566 246 542
2 1720 3792 383 844
2 4128 9100 747 1757
2 849 1872 214 472
2 1769 3900 246 542
2 3538 7800 201 443
2 3243 7150 663 1462
3 295 650 153 337
3 3243 7150 459 1012
3 1179 2600 338 745
3 1351 2979 93 205
3 2830 6240 307 677
3 1622 3575 367 809
3 2477 5460 612 1350
4 2973 6554 214 472
4 3240 7144 367 809
4 1179 2600 529 1166
4 5897 13000 134 295
4 5405 11916 306 675
4 2359 5200 306 675
4 2359 5200 536 1182
4 1474 3250 306 675
4 5897 13000 676 1490
4 1720 3792 918 2024
4 2654 5850 383 844
4 3928 8660 612 1350
4 2654 5850 918 2024
4 1179 2600 214 472
4 2108 4648 306 675
Total for all
drycleaning 77872 171678 12735 28078
Average 2512 5538 411 906
Number of drycleaners surveyed: 31
Average emission rate 20.7 kg perc/100 kg clothes
(continued)
49
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TABLE 4-2. (continued)
Number of
employees
Clothes processed per month
Perc consumed per month
kg
lb
kg
lb
Hamilton County
1 1237 2728 459 1012
1 786 1732 399 880
1 589 1299 246 542
1 412 909 80 176
1 1768 3897 16 35
1 1178 2598 306 675
2 1768 3897 485 1070
2 707 1559 99 218
2 1178 2598 612 1350
2 3535 7794 102 225
2 3535 7794 306 675
2 2455 5413 918 2024
2 1866 4113 459 1012
2 831 1833 230 507
2 589 1299 159 350
2 2946 6495 306 675
3 1964 4330 204 450
3 1178 2598 338 745
3 1178 2598 319 703
3 3535 7794 319 703
3 2357 5196 121 267
3 2357 5196 214 472
3 471 1039 121 267
3 2357 5196 612 1350
3 1326 2923 612 1350
3 2848 6279 204 450
3 2357 5196 612 1350
3 1473 3248 246 542
4 3535 7794 612 1350
4 3241 7145 1276 2813
4 907 2000 612 1350
4 2946 6495 306 675
4 2062 4547 121 267
4 3064 6755 612 1350
4 2357 5196 239 527
4 982 2165 105 231
4 3142 6928 319 703
4 2946 6495 319 703
4 3339 7361 214 472
(continued)
50
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TABLE 4.2 (continued)
Number of
employees
Clothes processed per month
Perc consumed per month
kg
lb
kg
lb
Dallas County
5
3361
7410
337
743
Hamilton County
4
4
4
4
4
4
4
1964
2357
2357
2946
1375
3534
1768
4330
5196
5196
6495
3031
7794
3897
319
159
319
121
928
1276
319
703
351
703
267
2046
2813
703
Total
93603
206371
17280
38102
Average
2035
4486
376
828
Number of drycleaners surveyed: 46
Average emission rate 22.1 kg perc/100 kg clothes
Average emission rate for both counties: 21.5 kg perc/100 kg clothes
51
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TABLE 4-3. COMMERCIAL DRYCLEANERS WITH S to 9 EMPLOYEES
Number of
employees
Clothes processed per month
Perc consumed per month
kg
lb
kg
lb
Dallas County
5 3361 7410 337 743
5 3241 7145 337 743
5 3241 7145 337 743
5 4717 10400 459 1012
5 3535 7794 612 1350
5 3402 7500 612 1350
5 3440 7584 306 675
5 4717 10400 338 745
5 2654 5850 491 1082
5 3685 8125 459 1012
5 3538 7800 319 703
6 2457 5417 430 948
6 3538 7800 663 1462
6 4128 9100 306 675
6 2359 5200 612 1350
6 3538 7800 1071 2361
6 2750 6062 399 880
7 4423 9750 1228 2707
7 5897 13000 459 1012
7 4128 9100 306 675
7 2064 4550 306 675
7 3440 7583 612 1350
7 5135 11320 918 2024
7 6486 14300 765 1682
7 2948 6500 459 1012
7 3243 7150 398 877
8 5897 13000 367 809
8 4177 9208 1212 2672
8 4717 10400 306 675
8 4717 10400 306 675
8 4717 10400 306 675
8 4717 10400 306 675
9 3784 8342 430 948
9 2160 4763 612 1350
9 5897 13000 612 1350
Total 136848 301698 17996 39677
Average 3910 8620 514 1134
Number of cleaners surveyed. 35
Average emission rate. 14.0 kg perc/100 kg clothes
(continued)
52
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TABLE 4-3. (continued)
Number of
employees
Clothes processed per month
Perc consumed per month
kg
lb
kg
lb
Hamilton
-County
5
3928
8660
1228
2707
5
3241
7145
638
1407
5
4419
9743
1531
3375
5
1964
4330
338
745
5
707
1559
319
703
5
4125
9093
520
1146
5
2357
5196
59
130
5
1178
2598
459
1012
5
3928
8660
306
675
5
2946
6495
306
675
6
1768
3897
204
450
6
2946
6495
1001
2207
6
5892
12990
612
1350
6
2357
5196
338
745
6
1964
4330
612
1350
7
11784
25980
319
703
7
5303
11691
319
703
Total
60807
134058
9109
20083
Average
3577
886
536
1181
Number of drycleaners surveyed. 17
Average emisson rate: 19.4 kg perc/100 kg clothes
Average emission rate for both counties: 15.8 kg perc/100 kg clothes
53
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TABLE 4-4. COMMERICAL DRYCLEANERS WITH 10 TO 19 EMPLOYEES
Number of
employees
Clothes processed per month
kg —— lb
Perc consumed per month
kg
lb
Dallas County
10 3784 8342 612 1349
10 5307 11700 612 1349
12 3784 8342 214 472
12 3784 8342 214 472
14 12383 27300 612 1349
14 4324 9533 612 1349
15 2457 5417 306 675
18 7076 15600 918 2024
19 11784 25980 995 2194
Total 54683 120556 5095 11233
Average 6076 13395 566 1248
Number of drycleaners surveyed: 9
Average emission rate: 10.2 kg perc/100 kg clothes
Hamilton County
10 1178 2598 408 900
10 11784 25980 1062 2341
10 3388 7469 306 675
10 3535 7794 1276 2813
12 2946 6495 612 1350
12 1375 3031 612 1350
12 6481 14289 765 1687
13 3928 8660 612 1350
Total 34615 76316 5653 12466
Average 4327 9540 707 1558
Number of drycleaners surveyed: 8
Average emission rate: 22 7 kg perc/100 kg clothes
Average emission rate for both counties: 16.1 kg perc/100 kg clothes
54
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TABLE 4-5. COMMERCIAL DRYCLEANERS WITH 2D EMPLOYEES
Number of
enipIoyees
Clothes processed per month
Perc consumed per month
kg
lb
kg
lb
Dallas
33
40
County
16511
3931
36400
8666
689
765
1519
1687
Total
20442
45066
1454
3206
Average
10221
22533
727
1603
Number
Average
of drycleaners surveyed: 2
emission rate: 11.8 kg perc/100 kg clothes
Dallas
24
County
5892
12990
918
2024
Average emission rate: 15.6 kg perc/100 kg clothes
Average emission rate for both counties: 13.1 kg perc/100 kg clothes
55
-------
0
0 0
0 0
0 0
o
o 0 o 2
o0 0
0
0
0
0
0 0
o 0
00
0
0 2002 0
0
0
00 300
Fiaure ft-2.
0
0
0
0
500 700 900
PERC CONSUMED (kg/month)
Clothes processed versus perc consumed by commerci0l
drycleaners in Dallas and Hamilton Counties (1 to 4
employees).
0
0
0
7,000
6,000
5,000
L i 000
3,000
2,000
1,000
C
0
E
w
It )
w
0
0
I -n
uJ
I—
0
-j
I -.)
0
0
0
0
0 00
0 0
0
0
0
0
0
0
1,100
56
-------
11 ,78
I I I ’ I I 1— — I I I I I i
7,000 —
U
6,000 —
00 0 0
0
5,000 —
4 0 0
— (1,531)
0 0
i,000 : 0 0 0 —
,ooo 0 0
2,000 0
0
0
1,000 —
C
I I I I I I I I I I I I
100 300 500 700 900 1,100
PERC CONSUMED (kglnonth)
Figure 4-3. Clothes prc,cessed versus oerc consumed by commercial
drycl aners in Odilas and Hamilton Counties (5 to 9
employees).
57
-------
12,383 11,78 14
Figure 4-4. Clothes processed versus perc consumed by commercial
drycleaning in Dallas and Hamilton Counties (10 to 19
employees).
-c
‘-I
C
0
E
-
C j
w
‘I ,
411
w
a:
I - f l
w
0
-J
100 300 500 700 900 1,100
PERC CONSUtiED (kg/month)
58
-------
17,500 I I I I I I 1 I
0
15,000 —
12,500
10,000 —
w
V)
1)
7,500 —
5;000
0
2,530 —
I I I I
100 300 500 700 900 1,100
PERC CONSUMED (kg/month)
Figure 4-5. Clothes processed versus perc consumed by commercial
drycleaners in Dallas and Hamilton Counties ( 20
employees).
59
-------
RECOMNENDAT IONS
In performing a demograhic study of an industry, PEDC0
recommends using the most recent issue of the CBP publication.
The yellow’ pages of the telephone directory are for a list of
local establishments in a particular industry. A list from an
organization that compiles business lists provides the same
information as the yellow pages but at an additional cost. The
primary advantage of using a commercially generated business list
is that is eliminates the risk of duplication in surveying.
Two other possible survey techniques are canvassing local
areas and mass mailing. Canvassing, however, requires personncl
resources, and mass mailing may fail to elicit response from a
significant number of establishments. Telephone contact, with
followup correspondence as necessary, is the recommended method.
60
-------
REFERENCES
1. U.S. Environmental Protection Agency. Control of Volatile
Organic Emissions from Perchioroethylene Dry Cleaning Sys-
tems, Guideline Series. Office of Air Quality Planning and
Standards. Research Triangle Park, N.C. EPA 450/2-78-050.
December 1978.
2. U.S. Department of Commerce. County Business Patterns,
1976. Bureau of the Census, Washington, D.C. 1976.
3. Standard Industrial Classification Manual, 1977 Supplement,
Executive Office of the President, Office of Management and
Budget. U.S. Department of Commerce, Office of Federal
Statistical Policy and Standards. 1972.
4. Gill, W., National Automatic Laundry and Cleaning Council,
Chicago, Illinois, Telephone conversation with W. Mason.
September 1979.
5. U.S. Environmental Protection Agency. Perchloroethylene Dry
Cleaning. Background Information for Proposed Standards
Office of Air Quality Planning and Standards. Research
Triangle Park, N.C. EPA 450/3-79—029a. August 1979.
6. King,C. Kleen-Rite Inc., St. Louis, M.O. Telephone conver-
sation with N. Anastas. September 17, 1979.
7. Personal communication to N. Anastas by an equipment manu-
facturer. August 7, 1979.
8. Sluizer, N. Telephone conversation with N. Anastas. Sep-
tember 28, 1979.
9. Stoddard, 3. Nultimatic Corp., Palisades Park, N.J. Tele-
phone conversation with N. Anastas. October 4, 1979.
10. General Services Administration. Worldwide Geographical
Location Codes. Office of Finance, Washington, D.C. Febru-
ary 1972.
11. Gill, W. Announcement at NAPCTAC meeting. August 1979.
12. PEDC0 Environmental, Inc. National Ambient Air Quality
Standards - States Attainment Status. unpublished survey,
1979.
13. U.S. Environmental Protection Agency. Federal Air Quality
Control Regions. Office of Air Programs, Rockville, M.D.
January 1972.
61
-------
14. Moss, S., Miracle Core Chemical Industries, Inc., Telephone
conversation with W. Mason. August 24, 1979.
15. Dow Chemical Company. What Every Drycleaner Should Know
About Perchioroethylene. Form No. 100-5437-77. 1977.
16. Watt,’ IV, and W. F. Fisher. Results of Membership Survey of
Dry Cleaning Operations. IFI Special Reporter No. 3-1,
January-February 1975. EPA 450/3-79-029a. 1975.
17. Kleeburg, C. F. Letter to J. F. Durham. Dry Cleaning Plant
Test at Texas Industrial Services, San Antonio, Tx. May 14,
1976.
18. Siu, R. Cintas Welcomes OSHA-EPA is Impressed. Textile
Retail. July 1979.
19. U.S. Environmental Protection Agency. Air Pollution Emis-
sion Test - Westwood Cleaners, Kalamazoo, M.I. Office of
Air and Waste Management, Office of Air Quality Planning and
Standards. Research Triangle Park, N.C. Report No. 76—DRY—3.
June 25, 1976.
20. Air Pollution Emission Test - Hershey Drycleaners and Laun-
dry, Hershey, P.A., Report No. 76-Dry-l, Contract
No. 68—02—1400, Task No. 21.
21. Air Pollution Emission Test - Texas Industrial Services,
San Antonio, Tx. Contract No. 68-02-1403, Task No. 21,
June 25, 1976.
22. Measurement of Volatile Organic Compounds. Guideline Ser-
vices No. 450/2—78041.
23. Mantell, C. L. Carbon and Graphite Handbook. Interscience
Publishers, New York. 1968.
24. Richards, D. W., and K. S. Surprenant. Study to Support New
Source Performance Standards for Solvent Metal Cleaning
Operations. Prepared for U.S. Environmental Protection
Agency. Office of Air Quality Planning, Contract
No. 68-02-1329, Task No. 9. June 1976.
25. Causes of Excessive Loss of Perchioroethylene. Internation-
al Fabricare Institute, Silver Spring, M.D. Bulletin No. 91,
1969.
26. Standard Method of Test for Dilution of Gasoline Engine
Crankcase Oils. American National Standards Institute.
62
-------
APPENDIX A
INVENTORIES OF COIN-OPERATED, COMNERCIAL
AND INDUSTRIAL DRYCLEANING ESTABLISHMENTS
AND OF PERC EMISSIONS
A-i
-------
TABLE A-i. COIN-OPERATED LAUNDRIES AND
DRYCLEANERS (SIC 7215) BY EPA REGION 2
Number
Number
of establishments by employment-size class
of
.
250
to
499
estab-
lish-
ments
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
EPA Regions
Region I
Connecticut 125 113 11 1
Maine 73 66 7
Massachusetts 230 192 29 6 3
New Hampshire 41 37 4
Rhode Island 57 48 8 1
Vermont 32 30 2
Subtotal 558 486 61 7 4
Region II
New Jersey 281 243 28 5 5
New York 902 819 51 25 6
Subtotal 1183 1062 79 30 11
Region III
Delaware 24 14 5 4 1
District of Columbia 30 24 5 1
Maryland 217 177 31 3 3 3
Pennsylvania 442 361 63 11 6
Virginia 280 241 33 5 1
West Virginia 109 97 ii 1
Subtotal 1102 914 148 24 12 4
(conti nued)
-------
TABLE A-i. (continued)
EPA Regions
Number
of
estab-
lish-
ments
Number
of establishments by employment-size class
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
Region IV
Alabama 206 183 iG 6 1
Florida 666 593 57 14 2
Georgia 229 199 25 2 3
Kentucky 265 233 29 i 1
Mississippi 148 141 6 1
North Carolina 331 298 25 5 1 2
South Carolina 168 150 13 4 1
Tennessee 280 255 19 5 1
Subtotal 2293 2052 190 38 9 1 3
Region V
Illinois 794 622 149 15 7 1
Indiana 489 382 90 16 1
Michigan 592 425 140 24 3
Minnesota 148 121 19 6 2
Ohio 674 540 110 17 7
Wisconsin 225 187 30 5 2 1
Subtotal 2922 2277 538 83 22 2
Region VI
Arkansas 146 139 7
Louisiana 132 115 13 2 2
New Mexico 96 72 17 7
Oklahoma 201 184 12 5
Texas 934 864 56 9 3 1
Subtotal 1509 1374 105 23 5 1
(conti nued)
-------
TABLE A-i. (continued)
Number
of
estab-
lish-
1
to
Number
4 5 to
of establishments by employment-size class
10 20 50 100 250
9 to to to to to
499
EPA Regions
ments
19
49
99
249
Region VII
Iowa 163 142 15 6
Kansas 169 143 21 5
Missouri 296 254 31 10 1
Nebraska 69 62 7
Subtotal 697 601 74 21 1
Region VIII
Colorado 152 131 17 3 1
Montana 46 39 6 1
North Dakota 25 23 1
South Dakota 40 39 1
Utah 68 55 12 1
Wyoming 30 27 2 1
Subtotal 361 314 39 5 2
Region IX
Arizona 119 103 12 2 2
California 614 484 91 28 9
Hawaii 38 34 4
Nevada 45 36 8 1
Subtotal 816 657 115 31 11
(continued)
-------
TABLE A-i. (continued)
EPA Regions
Number
of
estab-
lish-
ments
Number of establishments by employment-size class
1 to 4
5 to 9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
Region X
Alaska
Idaho
Oregon
Washington
Subtotal
Total United States
29
53
109
172
363
11804
17
44
87
137
285
10022
7
8
16
28
59
1408
2
1
5
6
14
276
3
1
4
81
1
1
10
6
1
U ’
-------
TABLE A-2. COMMERCIAL DRYCLEANING PLANTS
(SIC 7216, EXCEPT RUGCLEANERS) BY EPA REGION 2
Number
of
estab-
Number
of establishments by employment size class
10
20
50
100
250
lish-
1
to
4
5
to
9
to
to
to
to
to
EPA Regions
ments
19
49
99
249
499
Region I
Connecticut 346 208 81 45 12
Maine 50 36 4 7 3
Massachusetts 543 309 143 69 18 3
New Hampshire 47 29 10 7 1
Rhode Island 73 39 23 7 2 2
Vermont 33 16 7 8 2
Subtotal 1092 637 268 143 38 5
0• .
Region II
New Jersey 856 569 193 68 23 1 2
New York 2064 1450 424 145 33 8 4
Subtotal 2920 2019 617 213 56 9 6
Region III
Delaware 53 30 11 9 3
District of Columbia 103 50 27 18 8
Maryland 351 145 110 68 28
Pennsylvania 928 510 250 113 48 7
Virginia 554 277 172 74 26 5
West Virginia 126 64 39 16 7
Subtotal 2115 1076 609 298 120 12
(conti nued)
-------
TABLE A-2. (continued)
EPA Regions
Number
of
estab-
lish-
nients
Number
of establishments by employment-size class
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
Region IV
Alabama 400 238 98 47 14 2 1
Florida 661 347 201 82 28 2 1
Georgia 626 327 183 89 23 4
Kentucky 298 174 86 23 13 2
Mississippi 275 158 87 22 8
North Carolina 333 153 101 61 15 3
South Carolina 50 34 11 2 2 1
Tennessee 397 206 111 59 20 1
Subtotal 3040 1637 878 385 123 15 2
Region V
Illinois 919 481 247 141 41 5 4
Indiana 440 268 101 51 16 2 2
Michigan 754 411 212 102 26 2 1
Minnesota 254 139 69 29 15 2
Ohio 977 555 246 118 51 6 1
Wisconsin 336 213 84 27 8 3 1
Subtotal 3680 2067 959 468 157 20 9
Region VI
Arkansas 215 122 56 32 3 2
Louisiana 365 211 103 40 9 2
New Mexico 88 54 18 12 3 1
Oklahoma 264 180 51 20 9 3 1
Texas 1360 821 287 169 68 13 2
Subtotal 2292 1388 515 273 92 21 3
(continued)
-------
TABLE A-2. (continued)
EPA Regions
Number
of
estab-
lish-
ments
Number
of establishments by employment-size class
1
,to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
•
250
o
499
Region VII
Iowa 206 134 42 20 9 1
Kansas 229 156 54 15 4
Missouri 432 258 114 45 14 1
Nebraska 133 82 32 11 7
Subtotal 1000 630 242 91 34 2
Region VIII
Colorado 294 172 86 22 13 1
Montana 67 42 17 6 2
North Dakota 50 34 11 2 2 1
South Dakota 44 28 9 6 1
Utah 87 46 27 7 6 1
Wyoming 37 22 11 4
Subtotal 579 344 161 47 24 3
Region IX
Arizona 134 80 25 17 10 2
California 1826 1081 481 200 54 8 2
Hawaii 37 15 10 5 5 1
Nevada 52 17 12 17 6
Subtotal 2049 1193 528 239 75 11 3
(continued)
-------
TABLE A-2. (continued)
EPA Regions
Number{
of
estab-
lish-
ments
Number of establishments by erriployrnent-size class
T
1 to 4
5 to 9
10
to
19
20
to
49
50
to
99
100 250
to to
249 499
Region X
Alaska
Idaho
Oregon
Washington
Subtotal
Total United States
17
61
175
309
562
- 19953
9
36
126
202
373
11616
2
20
33
75
130
5106
2
4
12
26
44
2284
1
1
4
5
11
755
2
1
3
106 -—
1
1
26
—-
‘ 0
-------
TABLE A-3. COIN-OPERATED LAUNDRIES AND DRYCLEANERS
(SIC 7215) IN NONATTAINMENT AREAS BY STATE, 1 g 76 2 ’ 2 ’L3
Number
of
estab-
lish-
ments
1
to
Number
4 5 to
of establishments by employment-size class
10 20 50 100 250
9 to to to to to
19 49 99 249 499
EPA Regions
Region I
Connecticut 10 1 1 2 2 3 1
Maine 2 1 1
Massachusetts 23 3 1 3 8 5 2
New Hampshire 2 2
Rhode Island 2 2
Vermont 1 1
Subtotal 40 4 2 6 12 12 3
Region II
New Jersey 28 6 3 4 8 4 3
New York 63 11 9 7 19 15 2
Subtotal 91 17 12 11 27 19 5
Region III
Delaware 1 1
District of Columbia
Maryland 18 4 1 1 3 6 3
Pennsylvania 42 8 3 4 10 15 2
Virginia 18 2 2 4 3 4 3
West Virginia 4 1 1 2
Subtotal 83 15 6 9 17 28 8
(continued)
-------
TABLE A-3. (continued)
Number
Number
of establishments by employment-size class
of
estab-
lish-
ments
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
EPA Regions
Region IV
Alabama 16 2 3 7 3 1
Florida 35 2 4 5 9 9 6
Georgia 33 6 4 5 9 7 2
Kentucky 21 3 6 6 5 1
Mississippi 10 3 1 2 2 1 1
North Carolina 28 3 4 12 5 3 1
South Carolina 11 2 2 4 2 1
Tennessee 28 4 2 3 9 6 4
Subtotal 182 22 14 30 58 38 19 1
Region V
Illinois 45 8 2 5 15 10 5
Indiana 25 2 5 4 8 3 2 1
Michigan 46 6 6 14 11 3 5 1
Minnesota 11 3 3 2 1 2
Ohio 54 8 9 9 10 8 10
Wisconsin 11 3 2 2 3 1
Subtotal 192 30 27 34 47 27 25 2
Region VI
Arkansas 14 2 2 8 2
Louisiana 17 1 2 7 5 1 1
New Mexico 5 1 1 3
Oklahoma 14 1 2 2 5 4
Texas 62 5 5 5 22 18 6 1
Subtotal 112 9 8 11 43 32 7 2
(continued)
-------
TABLE A-3. (continued)
Number
of
estab-
Number of establishments by employment-size class
10
20
50
100
250
lish-
1
to
4
5
to 9
to
to
to
to
to
EPA Regions
nients
19
49
99
249
499
Region VII
Iowa 12 2 3 2 2 2 1
Kansas 15 2 5 2 2 4
Missouri 18 3 1 7 5 2
Nebraska 8 3 1 3 1
Subtotal 53 10 8 6 14 12 3
Region VIII
Colorado 11 3 1 1 2 4
Montana
North Dakota
South Dakota
Utah 3 1 1 1
Wyoming
Subtotal 14 4 2 1 3 4
Region IX
Arizona 10 2 1 3 3 1
California 103 16 3 12 34 24 14
Hawaii
Nevada 5 1 1 3
Subtotal 118 19 4 40 27
13
15
-------
TABLE A-3.
(conti ntied’)
-
EPA Regions
Number
of
estab-
lish-
ments
Number of establishments by employment-size class
1 to 4
,
5 to 9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
Region X
Alaska
Idaho
Oregon
Washington
Subtotal
Total United States
10
11
21
906
2 1
2 1
4 2
134 85
5 1
7
5 8
126 269
199
1
1
2
87
6
-------
TABLE A-4. TOTAL NUMBER COIN-OPERATED LAUNDRIES AND DRYCLEANERS
(SIC 7215) IN NONATTAINMENT AREAS BY STATE, 1976 2 ’12 ’L3
Number
of
estab-
lish-
Number
of establishments by employment-size class
1
to
4
5
to
9
10
to
20
to
50
to
100
to
250
to
State
ments
19
49
99
249
499
Alabama 69 54 11 4
Alaska
Arizona 16 14 2
Arkansas
California 342 252 59 23 7
Colorado 50 37 10 2 1
Connecticut 125 113 11 1
Delaware 12 4 4 4
District of Columbia 30 24 5 1
Florida 387 340 39 6 2
Georgia 58 51 7
Hawai i
Idaho
Illinois 521 398 106 10 7
Indiana 198 140 48 9 1
Iowa 10 8 1 1
Kansas 32 28 1 3
Kentucky 39 29 9
Louisiana 22 20 2
Maine 18 14 4
(conti nued)
-------
TABt E A-4. (continued)
State
Number
of
estab-
lish-
ments
Number
of establishments by employment-size class
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
Maryland 86 66 15 1 2 2
Massachusetts 230 192 29 6 3
Michigan 390 272 95 20 3
Minnesota 27 13 8 4 2
Mississippi
Missouri 97 78 11 8
Montana
Nebraska
Nevada 37 30 6 1
New Hampshire
ui New Jersey 281 243 28 5 5
New Mexico 29 23 4 2
New York 902 819 51 25 6
North Carolina 21 18 1 2
North Dakota
Ohio 303 224 60 14 5
Oklahoma 84 71 9 4
Oregon 29 19 7 2
Pennsylvania 442 361 63 11 6
Rhode Island 57 48 8 1
South Carolina 24 19 5
South Dakota
Tennessee 77 65 9 3
Texas 500 454 35 6 3
Utah 30 24 6
(conti nued)
-------
TABLE A-4. (continued)
State
Number
of
estab-
lish-
ments
Number of establishments by employment-size class
1 to 4
5 to 9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
United States
27
70
13
39
5724
18
53
10
30
4676
7
10
2
6
792
1 1
6 1
1
3
188 59
5
3
1
-------
TABLE A-5. COMMERCIAL DRYCLEANING PLANTS (SIC 7216,
EXCEPT RUGCLEANERS) IN NONATTAINMENT AREAS BY STATE 2 ’ 12 ’’ 3
Number
of
estab-
lish-
1
to
Number
4 5 to
of establishments by employment-size class
10 20 50 100 250
9 to to to to to
State
ments
19
49
99
249
Alabama 148 36 37 26 9
Alaska
Arizona 30 19 5 3 3
Arkansas 40 10 14 11 3 2
California 1383 779 376 169 49 8 2
Colorado 220 123 71 16 9 1
Connecticut 346 208 81 45 12
Delaware 39 20 9 9 1
District of Columbia 103 50 27 18 8
Florida 434 220 135 53 23 2
Georgia 346 179 103 48 12 4
Hawaii
Idaho
Illinois 715 329 209 128 40 5 4
Indiana 200 112 44 32 8 2 2
Iowa 52 23 12 10 7
Kansas 95 53 30 11 1
Kentucky 130 61 45 12 11 1
Louisiana 201 108 58 28 5 2
Maine 15 8 2 3 2
(continued)
-------
TABLE A-5. (continued)
Number
of
estab-
lish-
1
to
Number
4 5 to
of establishments by employment-size class
10 20 50 100 250
9 to to to to to
State
ments
19
49
99
249
499
Maryland 217 78 73 46 20
Massachusetts 543 309 143 69 18 3 1
Michigan 614 320 181 88 22 2 1
Minnesota 154 65 54 22 11 2
Mississippi
Missouri 179 88 54 27 9 1
Montana 17 12 4 1
Nebraska 43 25 6 7 4 1
Nevada 46 16 11 13 6
New Hampshire 29 16 6 6 1
New Jersey 856 569 193 68 23 1 2
New Mexico 31 15 8 7 1
New York 2064 1450 424 145 33 8 4
North Carolina 62 30 19 7 5 1
North Dakota
Ohio 769 421 194 101 48 4 1
Oklahoma 109 56 30 11 8 3 1
Oregon 97 59 25 10 3
Pennsylvania 928 510 250 113 48 7
Rhode Island 73 39 23 7 2 2
(continued)
-------
I- ’
TABLE A-5.
(continued)
State
Number
of
estab-
lish-
ments
Number of establishments by employment-size class
•
1 to 4
5 to 9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
United States
83
206
757
68
14
309
188
18
178
13149
16
87
392
31
5
149
123
3
110
7372
34
59
176
24
3
95
46
10
43
3446
24
42
121
7
5
46
16
1
15
1647
7
17
53
5
1
14
3
4
7
576
2
1
13
1
5
2
85
2
1
23
-------
Alabama
Alaska
Arizona
Arkansas
Cali fornia
Colorado
Connecticut
Delaware
District
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
TABLE A-6. INDUSTRIAL LAUNDERIES (SIC 7218)
IN NONATTAINMENT AREAS BY STATE, 19762 12 13
5
11
8
1
3
3
3
1
Number
of
estab
lish
Number
of establishments by employment size class
1
to
4
5
to
9
10
to
20
to
50
to
100
to
250
to
State
ments
19
49
99
249
499
0
of Columbia
8
1
4
77
4
10
1
29
12
32
8
2
2
22
1
3
1
9
4
10
2
13
1
1
1
2
6
1
3
1
3
3
1
1
1
2
9
2
4
2
1
3
1
4
2
18
2
2
7
1
8
3
1
4
1
1
12
1
5
2
5
1
1
1
1
(conti nued)
-------
TABLE A-6. (continued)
Number
of
estab-
lish-
Number
of establishments by employment-size class
•
1
to
4
5
to
9
10
to
20
to
50
to
100
to
250
to
State
ments
19
49
99
249
499
Maryland 5 2 2 1
Massachusetts 23 3 1 3 8 5 2
Michigan 32 4 3 8 9 2 5
Minnesota 5 2 1 2
Mississippi
Missouri 6 1 1 3 1
Montana
Nebraska 2 2
Nevada 3 3
New Hampshire 2 2
New Jersey 28 6 3 4 8 4 3
New Mexico 1 1
New York 63 11 9 7 19 15 2
North Carolina 5 2 1 1 1
North Dakota
Ohio 44 6 5 7 9 1 10
Oklahoma 10 1 1 4 4
Oregon 5 1 2 1 1
Pennsylvania 42 8 3 4 10 15 2
Rhode Island 2 2
(conti nued)
-------
TABLE A-6. (continued)
F ’ )
F ’ )
State
Number
of
estab-
lish-
ments
Number of establishments by employment-size class
— —_________
ito 4
5 to 9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
United States
2
18
36
2
7
1
4
559
2
2
1
74
1
2
41
1
1
3
65
5
12
1
2
1
154
1
6
11
4
2
151
3
5
1
1
1
69
1
5
-------
TABLE A-7. COIN-OPERATED LAUNDRIES AND DRYCLEANERS
(SIC 7215) IN ATTAINMENT AREAS BY STATE, 1976
Number
of
Number
of establishments by ernpl oyment-s ize class
20
50
100
250
estab-
to
lish-
1
to
4
5
to
9
to
to
to
State
merits
19
49
99
249
499
Alabama 137 129 5 2 1
Alaska 29 17 7 2 3
Arizona 103 89 10 2 2
Arkansas 146 139 7
California 272 232 32 5 2
Colorado 102 94 7 1
Connecticut
Delaware 12 10 1 1
District of Columbia
Florida 279 253 18 8
Georgia 171 148 18 2 3
Hawaii 38 34 4
Idaho 53 44 8 1
Illinois 273 224 43 5
Indiana 291 242 42 7
Iowa 153 134 14 5
Kansas 137 115 20 2
Kentucky 226 204 20 1
Louisiana 110 95 13 2
Maine 55 52 3
(conti nued)
-------
TABLE A-7. (continued)
Number
of
estab-
lish-
Number
of establishments by employment-size class
1 to
4
5
to
9
10
to
20
to
50
to
100
to
250
to
State
ments
19
49
99
249
499
Maryland 131 111 16 2
Massachusetts
Michigan 202 153 45 4
Minnesota 121 108 11 2
Mississippi 148 141 6 1
Missouri 199 176 20 2
Montana 46 39 6
Nebraska 69 62 7
Nevada 8 6 2
New Hampshire 41 37 4
New Jersey
New Mexico 67 49 13 5
New York
North Carolina 310 280 24 3 1 2
North Dakota 25 23 1
Ohio 371 316 50 3 2
Oklahoma 117 113 3 1
Oregon 80 68 9 3
Pennsyl vani a
Rhode Island
(conti nued)
-------
TABLE A-i. (continued)
U,
State
Number
of
estab-
lish-
ments
Number of establishments by employment-size class
•
1 to 4
5 to 9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
United States
144
40
203
434
38
32
253
102
96
186
30
6080
131
39
190
410
31
30
223
84
87
157
27
5346
8
1
10
21
6
2
26
18
9
24
2
616
4
2
3
1
4
2
1
88
1
1
2
22
1
5
3
-------
TABLE A-8. COMMERCIAL DRYCLEANERS (SIC 7216)
IN ATTAINMENT AREAS BY STATE, 1976
Number
of
estab-
lish-
rnents
1 to
Number
4 5 to
of establishments by employment-size class
10 20 50 100 250
9 to to to to to
19 49 99 249 499
State
Alabama 252 162 61 21 5 2
Alaska 17 9 2 2 1 2
Arizona 104 61 20 14 7 2
Arkansas 175 112 42 21
California 443 302 105 31 5
Colorado 74 49 15 6 4
Connecti cut
Delaware 14 10 2 2
District of Columbia
Florida 227 127 66 29 5
Georgia 280 148 80 41 11
Hawaii 37 15 10 5 5 1
Idaho 61 36 20 4 1
Illinois 204 152 38 13 1
Indiana 240 156 57 19 8
Iowa 154 111 30 10 2 1
Kansas 134 103 24 4 3
Kentucky 168 113 41 11 2 1
Louisiana 164 103 45 12 4
Maine 35 28 2 4 1
(continued)
-------
TABLE A-B. (continued)
Number
of
estab-
lish-
Number
of establishments by employment-size class
1 to
4
5
to
9
10
to
20
to
50
to
100
to
250
to
State
ments
19
49
99
249
499
Maryland 134 67 37 22 8
Massachusetts
Michigan 140 91 31 14 4
Minnesota 100 74 15 7 4
Mississippi 275 158 87 22 8
Missouri 253 170 60 18 5
Montana 50 30 13 5 2
Nebraska 90 57 26 4 3
New Hampshire 18 13 4 1
New Jersey
New Mexico 57 39 10 5 2
New York
North Carolina 612 316 191 78 22 5
North Dakota 50 34 11 2 2
Ohio 208 134 52 17 3 2
Oklahoma 155 124 21 9 1
Oregon 78 67 8 2 1
Pennsylvani a
Rhode Island
(conti nued)
-------
TABLE A-8. (continued)
State
Number
of
estab-
lish-
ments
Number of establishments by employment-size class
—
10 20 50 100 250
1 to 4 5 to 9 to to to to to
19 49 99 249 499
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
United States
250
44
191
603
19
19
245
121
108
158
37
6804
137
28
119
429
15
11
128
79
61
103
22
4304
67
9
52
111
3
4
77
29
29
41
11
1660
37
6
17
48
3
28
10
15
12
4
637
8
1
3
15
1
1
12
2
3
1
79
1
1
1
21
3
-------
TABLE A-9. INDUSTRIAL LAUNDERERS (SIC
7218) IN ATTAINMENT AREAS BY STATE, 1976
Number
of
estab-
lish-
1
to
Number
I
4 5 to
of establishments by employment-size class
10 20 50 100 250
9 to to to to to
State
ments
19
49
99
249
499
Alabama 8 2 1 3 1
Alaska
Arizona 9 2 1 3 3
Arkansas 10 2 2 6
California 26 3 3 16 2 2
Colorado 7 2 1 1 3
Connecti cut
Delaware
District of Columbia
Florida 6 1 1 1 2
Georgia 21 4 1 5 8 3
Hawaii
Idaho
Illinois 13 2 1 3 7
Indiana 17 2 4 3 5 1 2
Iowa 12 2 3 2 2 2
Kansas 10 2 4 2 1 1
Kentucky 10 3 3 2 2
Louisiana 9 1 6 2
Maine 1 1
(conti nued)
-------
TABLE A-9. (continued)
Number
of
estab-
Number
of establishments by employment-size class
10
20
50
100
250
lish-
1
to
4
5
to
9
to
to
to
to
to
State
ments
19
49
99
249
499
Maryland 13 4 1 1 1 4 2
Massachusetts
Michigan 14 2 3 6 2 1
Minnesota 6 1 3 2
Mississippi 10 3 1 2 2 1
Missouri 12 2 1 6 2
Montana
Nebraska 6 3 1 1 1
Nevada 2 1 1
New Hampshire
0
New Jersey
New Mexico 4 1 1 2
New York
North Carolina 23 1 4 11 4 2
North Dakota
Ohio 10 2 4 2 1 1
Oklahoma 4 1 1 1 1
Oregon 5 1 1 3
Pennsyl vani a
Rhode Island
(conti nued)
-------
TABLE A-9. (continued)
State
Number
of
estab-
lish-
ments
Number of establishments by employment-size class
I
1 to 4 5 to 9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
Maryland
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
United States
13
9
10
26
1
1
11
10
4
7
347
4
2
2
3
2
2
1
3
60
1
1
3
1
2
1
2
44
1
1
2
2
4
61
1
4
4
10
1
7
1
1
115
4
1
7
1
2
1
48
2
1
1
1
2
18
1
-------
TABLE A-lU.
1976 PERC EMISSIONS BY EPA REGIONS (Mg)
EPA Region
Coin-op
Commercial
Industrial
Region I
Connecticut 174.2 1729.1 149.8
Maine 101.7 250.6 30.0
Massachusetts 320.6 2743.5 344.6
New Hampshire 57.1 233.0 30.0
Rhode Island 79.4 371.6 30.0
Vermont 44.6 180.9 15.0
Subtotal 777.6 5508.7 599.4
Region II
New Jersey 391.6 4111.2 419.5
New York 1257.1 9706.5 943.8
Subtotal 1648.7 13817.7 1363.3
Region III
Delaware 33.4 276.8 15.0
District of Columbia 41.8 558.0
Maryland 302.4 1946.1 269.7
Pennsylvania 616.0 4780.0 59.9
Virginia 390.2 2887.7 269.7
West Virginia 151.9 653.7 59.9
Subtotal 1535.7 11102.3 1243.5
Region IV
Alabama 287.1 2005.7 239.7
Florida 928.2 3386.3 524.3
Georgia 319.2 3221.5 494.4
Kentucky 369.3 1483.4 314.5
Mississippi 206.3 1345.6 149.8
North Carolina 461.3 3470.7 419.5
South Carolina 234.1 1781.9 164.8
Tennessee 390.2 2068.3 419.5
Subtotal 3195.7 18763.4 2726.6
Region V
Illinois 1106.6 4799.3 674.2
Indiana 681.5 2204.5 374.5
Michigan 825.1 3834.4 689.1
Minnesota 206.3 1314.1 164.8
Ohio 939.4 5011.7 809.0
Wisconsin 313.6 1633.8 164.8
Subtotal 4072.5 18797.8 2876.4
A-32
(conti nued)
-------
TABLE A—1O. (continued)
EPA Region
Coin-•op
Commercial
Industrial
Region VI
Arkansas 203.5 1079.0 209.7
Louisiana 184.0 1809.2 254.7
New Mexico 133.8 444.3 74.9
Oklahoma 280.1 1284.7 209.7
Texas 1301.7 6946.0 928.8
Subtotal 2103.1 11563.2 1677.8
Region VII
Iowa 227.2 1017.9 179.8
Kansas 235.5 1075.1 224.7
Missouri 412.5 2137.1 269.7
Nebraska 96.2 665.2 119.9
Subtotal 971.4 4895.3 794.1
Region Viii
Colorado 211.8 1457.9 164.8
Montana 64.1 325.7
North Dakota 34.8 242.2
South Dakota 55.7 216.3
Utah 94.8 451.2 44.9
Wyoming 41.8 177.4
Subtotal 503.0 2870.7 209.7
Region IX
Arizona 165.9 704.2 149.8
California 855.7 9066.6 1543.1
Hawaii 53.0 220.1
Nevada 62.7 316.5 74.9
Subtotal 1137.3 10307.4 1767.8
Region X
Alaska 40.4 102.0
Idaho 73.9 291.9
Oregon 151.9 820.0 149.8
Washington 239.7 1474.7 164.8
Subtotal 505.9 2688.6 314.6
Total 16450.9 100315.1 13573.2
A-33
-------
TABLE A-il. 1976 PERC EMISSION iN NONATTAINMENT AREAS, METRIC TONS
State
Coin_opt
Commercial
Industrial
Alabama 96.2 I 785.9 119.9
Alaska - — -- —-
Arizona 22.3 156.3 15.0
California 476.6 6995.9 1153.6
Colorado 69.7 1093.7 59.9
Connecticut 174.2 1729.1 149.8
Delaware 16.7 205.2 15.0
District of Columbia 41.8 558.0 --
Florida 539.4 2256.6 434.5
Georgia 80.9 1785.0 179.8
Hawaii -- -- — -
Idaho -- -- --
Illinois 726.1 3868.3 479.4
Indiana 276.0 1044.8 119.9
Iowa 13.9 300.1 --
Kansas 44.6 465.3 74.9
Kentucky 54.4 692.9 164.8
Louisiana 30.7 1022.1 119.9
Maine 25.1 85.3 15.0
Maryland 119.9 1236.5 74.9
Massachusetts 320.6 2743.5 344.6
1ichigan 543 6 3155.0 479.4
Minnesota 37 6 839.2 74.9
Mississippi -- -- --
Missouri 135.2 941.1 89.9
Montana -- 77.7 --
Nebraska -- 235 4 30.0
Nevada 51.6 277.9 44.9
New Hampshire -- 151.1 30.0
New Jersey 391.6 4111.2 419.5
New Mexico 40.4 164.7 15.0
New York 1257.1 9706.5 943.8
North Carolina 29.3 333.5 74.9
North Dakota -- -- —-
Ohio 422.3 4013.5 659.2
Oklahoma 117.1 587.0 149 8
Oregon 40 4 476 8 74.9
Pennsylvania 616.0 4780.0 629.2
Rhode Island 79.4 371.6 30.0
A-i 4
-------
TABLE A-li. (continued)
State
Coin op
Commercial
Industrial
South Carolina
33.4
507.5
30.0
South Dakota
Tennessee
107.3
1152.0
269.7
Texas
696.9
4095.2
539.3
Utah
41.8
363.6
30.0
Vermont
82.7
Virginia
37.6
1634.5
104.9
Washington
97.6
894.4
15.0
West Virginia
18.1
111.4
Wisconsin
54.4
887.3
59.9
Wyoming
United States
7977.7
67219.4
8375.0
-------
TABLE A-12. 1976 PERC EMISSIONS IN ATTAINMENT AREAS (Mg)
State —
Coin op
Commercial
Industrial
Alabama 190.9 1219.8 119.8
Alaska 40.4 102.0
Arizona 143.6 547.9 134.8
Arkansas 203.5 834.9 149.8
California 379.1 2070.7 389.5
Colorado 142.1 364.2 104.9
Connecticut
Delaware 16.7 71.6
District of Columbia
Florida 388.8 1129.7 89.8
Georgia 238.4 1436.5 314.6
Hawaii 53.0 220.1
Idaho 73.9 291.9
Illinois 380.5 931.0 194.8
Indiana 405.5 1159.7 254.7
Iowa 213.3 717.8 179.8
Kansas 190.9 609.8 149.8
Kentucky 314.9 790.5 149.8
Louisiana 153 3 787.1 134.8
Maine 76.6 165.3 15.0
Maryland 182.5 709.6 194.8
NTa s sac h use t t s
Michigan 281.5 679.4 209.7
Minnesota 168.7 474.9 89.9
Mississippi 206.3 1345.6 149.8
Missouri 277.3 1196.0 179.8
Montana 64 1 248.0
Nebraska 96.2 429.8 89.9
Nevada 11.1 38 6 30.0
New Hampshire 57.1 81.9
New Jersey
New Mexico 93.4 279.6 59.9
New York
North Carolina 432.0 3137.2 344.6
North Dakota 34.8 242.2
Ohio 517.1 998.2 149.8
Oklahoma 163.0 697.7 59.9
Oregon 111.5 343.2 74.9
Pennsylvania
Rhode Island
(conti nued)
A-3G
-------
TABLE A-12. (continued)
State
Coin op
Commercial
Industrial
South Carolina
200.7
1274.4
134.8
South Dakota
55.7
216.3
Tennessee
282.9
916.3
149.8
Texas
604.8
2850.8
389.5
Utah
53.0
87.6
14.9
Vermont
44.6
98.2
15.0
Virginia
352.6
1253.2
164.8
Washington
142.1
580.3
149.8
West Virginia
133.8
542.3
59.9
Wisconsin
259.2
746.5
104.9
Wyoming
41.8
177.4
United States
8473.2
33095.7
5198.2
A-37
------- |