OVERVI&^pjSWf |^|y of the DRYCL^JP I ffiNDUSTR? by PEDCo ENVIRONMENTAL ------- PEDCo ENVIRONMENTAL, INC. P.O. BOX 20337 DALLAS. TEXAS 75220 (214) 259-3577 TELEX (214) 254-4021 OVERVI&M DRYCLE^j Y OF THE NDUSTRY by PEDCo Environmental, Inc. P. 0. Box 20337 Dallas, Texas 75220 Contract No. 68-01-4147 Task No. 101 John R. Busik, Project Officer Robert L. King, Task Manager U.S. ENVIRONMENTAL PROTECTION AGENCY DIVISION OF STATIONARY SOURCE ENFORCEMENT WASHINGTON, D.C. 20460 November 1979 CORPORATE OFFICE u TOWERS 1 1 499 CHESTER ROAD CINCINNATI. OHIO 45246 (51 3) 782-4700 ------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 NOV 2 3 1979 OFFICE OF ENFORCEMENT SUBJECT: Transmittal of Draft Document - Overview Survey of the Drycleaning Industry FROM: Director, Division of Stationary Source Enforcement TO: Director, Enforcement Division, Regions I-X Director, S&A Division, Regions .I-X Director, Air & Hazardous Materials Divisions, Regions J-X Director, Control Programs Development Division, OAQPS Director, Emission Standard & Engineering Division, OAQPS DSSE has requested that PEDCo review the Control Technique "Guidelines for the perchloroethylene (perc) dry cleaning industry to: (1) establish essential character- ization of the industry (2) trends in growth patterns of the industry, (3) review emission control technology and factors affecting enforcement, and (4) to develop a methodology of identifying and quantifying emission sources. The attached report is a summary of preliminary findings of this effort. Additionally, PEDCo is studying methodologies for reducing the heavy workload required for initial compliance of the various control systems. While we realize that the majority of the perc dry- cleaning industry will be minor sources of VOC, we are concerned that all possible effort be made to develop highly efficient and effective methodologies for compliance monitoring of this category. Any comments, suggestions, or problems should be directed to Robert L. King (FTS 755-2582) of my staff. Attachment ------- DISCLAIMER This report was furnished to the U.S. Environmental Protec- tion Agency by PEDCo Environmental, Inc., in fulfillment of i 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 ------- CONTENTS Page Figures iv Tables v Acknowledgment vi 1. Introduction 1 2. Industry Characterization 4 3. Control Technology and Factors Affecting Its Enforcement 33 4. Methodology of Identification and Quantitation of Emission Sources 45 References 66 Appendix Coin-operated, commercial, and industrial dry- cleaning establishment inventory and perc emissions inventory 68 iii ------- FIGURES Number Page 2-1 Commercial Perc Drycleaning Plant Flow Diagram, With Paper Cartridge Filter and Carbon Adsorber 9 2-2 Flow Diagram Of Industrial Drycleaning Operation 11 4-1 Drycleaning Industry Data Sheet 48 4-2 Clothes Processed Versus Perc Consumed By Commercial Drycleaners In Dallas And Hamilton Counties (1 to 4 Employees) 62 4-3 Clothes Processed Versus Perc Consumed By Commercial Drycleaners In Dallas And Hamilton Counties (5 to 9 Employees) 63 4-4 Clothes Processed Versus Perc Consumed By Commercial Drycleaners In Dallas And Hamilton Counties (10 to 19 Employees) 64 4-5 Clothes Processed Versus Perc Consumed By Commercial Drycleaners In Dallas And Hamilton Counties 20 Employees) 65 IV ------- TABLES Number Page 2-1 Summary List - Coin-operated Laundries and Drycleaners In The U.S., 1976 15 2-2 Summary List - Commercial Drycleaners In The U.S., 1976 16 2-3 Summary List - Industrial Laundries and Drycleaners In The U.S., 1976 17 2-4 Summary of Emission Factors and Weight of Cloth- ing Cleaned Per Establishment 25 2-5 Summary List - 1976 Emissions From Perc Dry- cleaners, Metric Tons 26 2-6 Perchloroethylene Emission Factors Before and After Application Of RACT, kg/100 kg Of Clothes 32 4-1 Dallas County Drycleaners Using Carbon Adsorbers 50 4-2 Dallas County Survey: Commercial Drycleaners With 1 to 4 Employees 52 4-3 Hamilton County Survey: Commercial Drycleaners With 1 to 4 Employees 53 4-4 Dallas County Survey: Commercial Drycleaners With 5 to 9 Employees 55 4-5 Hamilton County Survey: Commercial Drycleaners With 5 to 9 Employees 56 4-6 Dallas County Survey: Commercial Drycleaners With 10 to 19 Employees 57 4-7 Hamilton County Survey: Commercial Drycleaners With 10 to 19 Employees 58 4-8 Dallas County Survey: Commercial Drycleaners With t 20 Employees 59 4-9 Hamilton County Survey: Commercial Drycleaners With S 20 Employees 60 v ------- 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, Cynthia M. Harvey, K. Wade Mason, and Mary A. Taft. Task Manager for the U.S. Environmental Protection Agency was Mr. Robert L. King. vi ------- SECTION 1 INTRODUCTION 1.1 BACKGROUND The Clean Air Act Amendments (CAAA) of 1977 required each state to report 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 Regis- ter on March 3, 1978. According to the 1977 CAAA, nonattainment areas must achieve compliance with NAAQS by December 31, 1982, with some possible extensions to 1987. In December 1978, a Control Technique Guideline (CTG) was published for control of Volatile Organic Compounds (VOC) from perchloroethylene (perc) drycleaning systems. Those industries in areas where standards covering a particular pollutant are not being met will be required to apply Reasonably Available Control Technology (RACT). This required technology is discussed in the subject CTG. 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 State Implementation Plan (SIP) revi- sions reflecting RACT for perc drycleaning systems. Promulgation of the regulations is required by July 1, 1980. The new regula- tions will involve state and local agencies with an industry which previously has had little or no air pollution control enforcement activity. Previous state regulations pertaining to organic solvents, specifically Rule 66 of the Air Pollution Control District County of Los Angeles, California and Part 205 of the New York City Metropolitan Area, have always exempted perc 1 ------- from emission limitations. However, Part 212 of the New York City Metropolitan Area Regulations does provide some limitations to perc emissions from drycleaning facilities. 1.2 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 the Division of Stationary Source Enforcement (DSSE), and by 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. The status (attainment or nonattain- ment) for photochemical oxidants is given for each area in this inventory. 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. Projections of the number of drycleaning plants and potential perc emissions are made for 1980, 1985, and 1990 from the base numbers. Base numbers were obtained from the 1976 County Business Pattern Publication of the Bureau of Census, a survey of drycleaning establishments in Dallas County, Texas, and Hamilton County, Ohio, and the CTG. Section 3 describes the control technology for perc dryclean- ing facilities and the factors affecting the enforcement of RACT. In addition, a review of the enforcement aspects of the proposed model regulation is provided. This is only a preliminary overview of the problems associated with application and compliance moni- toring of RACT. More specific problems will be addressed in future phases of this study on perc drycleaners. Section 4 provides PEDCo's methodology for identifying and quantifying the number of emission sources. The sources of information used are discussed and the results of the Dallas County and Hamilton County surveys are given. Recommendations for future demographic studies are also provided. 2 ------- 1.3 SUMMARY OF FINDINGS This survey indicates a total number of 32,663 laundry and drycleaning establishments located in the United States as of 1976. Of the drycleaning establishments, those using perc in the three industry sectors are: 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 reported to be 158,000 metric ton (174,000 ton). The number of drycleaners using other solvents is as follows: 133 coin-ops using freon, 4789 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 liquid leaks, and to reduce the perc content in waste materials. Control technology includes the use of a carbon adsorber or equally effective control device on the dryer exhaust, increased maintenance to detect and immediately repair liquid leaks, and suitable operation of stills, muck cookers, and filter cartridges to reduce the perc content in the waste materials before disposal. Coin-operated facilities and those with space or steam capacity limitations are exempted 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. Leak inspections and inspections to determine if proper operating procedures which reduce perc contents in wastes are being followed are time con- suming and may be impractical when the total number of sources is very large. A specified mileage standard for each classification may circumvent these difficulties. 3 ------- SECTION 2 INDUSTRY CHARACTERIZATION 2.1 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. These three industries are: ° Coin-operated laundries and drycleaners (SIC code 7215) ° Drycleaning plants, except rugcleaning (SIC code 7216) 0 Industrial launderers (SIC code 7218) The services provided by these industries include cleaning of apparel, household fabrics, and work uniforms. A brief descrip- tion of each is given in the following paragraphs. 2.1.1 Coin-operated Laundries and Drycleaning Establishments (SIC 7215) Coin-operated laundries (coin-ops) have been given the following definition in the Standard Industrial Classification Manual.1 "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 by the fact that the drycleaning equipment is activated by the customer1. In many cases, the manager or attend- ant of the coin-op will assist the customer in drycleaning the clothes. Coin-ops are normally part of a laundromat facility and can be operated on an independent or franchi.se basis. They provide a low cost [approximately $1.10 per kg (50 cents per lb)2 4 ------- of clothes] self-service type of drycleaning without pressing, spotting, or other services provided by commercial drycleaners. A typical coin-operated drycleaning establishment processes ap- proximately 9,050 kg (20,000 lb) of clothes per year, for an average annual gross income of $10,000 per year.3 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 systems.4 Fluorocarbon machines account for the remaining 2.5 percent of the coin-op systems; there are no petroleum coin-operated machines, due to the flammability of the petroleum solvents. The drycleaning units that are 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 present in the perc and the clay adsorbs nonvolatile residues (NVR).5 2.1.2 Drycleaning Plants, Except Rugcleaning (SIC 7216) Establishments in this industry are often referred to as commercial drycleaners. The definition of this SIC code is as follows:1 "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 include small neighborhood drycleaners operating on an independent basis, franchised shops, and specialty cleaners which clean leather and other fine goods. These cleaners typically process about 17,700 kg (39,000 lb) of clothes per year.3 The range is from less than 9,000 kg to greater than 45,000 kg 5 ------- (20,000 lb to greater than 100,000 lb) per year. The majority of these plants have 1 to 15 employees; typically four to six employ- ees . Perc is the predominant drycleaning solvent used by the commercial drycleaners. Seventy-two percent of all commercial drycleaners use perc; twenty-four percent use Stoddard solvent; and 4 percent use fluorocarbons. Three basic steps are used by all these plants in the clean- ing process: washing, extraction, 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 manufactured carry out the washing and extraction steps and then the clothes are transferred to the dryer. In the dry-to-dry machines the washing, extraction, and drying steps are all carried out in the same machine. The dry-to- dry machine has been used very little in the past in commerical perc plants because machine utilization is only half that of the transfer type. The washer and dryer can be used simultaneously with the transfer machine. Currently there is increasing interest in the dry-to-dry type because it can meet OSHA regulations more easily; it requires less attention during the cleaning cycle than the transfer type. Furthermore, the equipment manufacturers are putting more effort into improving and selling this type. Pre- sently, about 25 percent of the plants have dry-to-dry machines.3 In the washing step, one or two solvent baths may be used, although the majority of the commercial cleaners use only one bath. The use of a two-bath system generally improves overall cleaning efficiency. To aid in removing water soluble soils, small amounts of detergent (and sometimes water) are added to the solvent in the one bath system. For both types of machine, in the extraction step, the sol- vent bath is drained, and then the -clothes are spun at a high speed to wring out excess solvent. Most of the newer transfer machines are washer-extractor types; thus the washing and extrac- tion steps are the same as in the dry-to-dry machines. 6 ------- After the extraction step the procedure differs with the two types of machines. With the transfer machines the clothes are tranferred to the dryer-reclaimer. With the dry-to-dry machines the drying step is performed in the same unit. Currently OSHA regulations require that fresh air be blown across the transfer machine operator when transferring clothes from the washer-extrac- tor to the dryer. This is accomplished by an exhaust fan pulling air into the washer and dryer doors and away from the operator when the doors are open. In the drying step perc plants always use a solvent reclaim- ing dryer. This is accomplished by blowing heated air 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 their dryer exhausts to recover perc for economic reasons. During the washing cycle, perc is passed through a filter to remove suspended matter and dyes. The filter may be either a paper cartridge type or regenerative type. The paper cartridge filters, usually containing some activated carbon for removal of dyes, are re-used for several wash cycles and are drained before they are discarded. The regenerative filter is regenerated by backwashing the filter powder precoat and adding a new precoat. The backwash contains diatomaceous earth, activated carbon, suspended matter removed from the perc, and a considerable amount of perc which must be recovered. Perc recovery is usually accom- plished 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 NVR, such as oils and fats, from the perc is accomplished in a unit, which distills the perc from the impurities 7 ------- which are discarded as still bottoms. Distillation of all or part of the solvent is periodically necessary in order to prevent buildup of these soluble impurities. A typical commercial perc plant would have one washer-extrac- tor of 25 or 50 pound capacity, one or two reclaiming dryers of equivalent size, a solvent filter with disposable paper cartridges, and a distillation unit. Figure 2-1 is a process flow diagram for a typical commerical perc drycleaning plant. 2.1.3 Industrial Launderers (SIC 7218) ' The definition of SIC code 7218 for establishments within this industry is as follows:1 "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 work uniforms, executive shirts and slacks, wiping towels, treated rugs, and other textiles to 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 (using either Stoddard or perc) because longer wear is achieved when drycleaning than when laundering, and in some cases the aggressive action of the solvents toward heavily greased items produce superior re- sults.6'7 However, laundering (water and detergent) is indispen- sible in the removal of water-solubles such as perspiration odors. It is not uncommon for some launderers to employ a dual phase cleaning process consisting of an initial water wash fol- lowed by a solvent wash and rinse.6'7 Some industrial launderers provide a number of dust control items for industry. These items are used in the maintenance of 8 ------- Figure 2-1. Commercial oerc drycleaning plant flow diagram, with paper cartridge filter and carbon adsorber. ------- machinery and its controls, in prevention of soiling of finished products, and in dust control within working areas. These services may be: 0 Wiping towels, which are a specially woven fabric, for use in applications where no lint or any residues may be tolerated. ° Chemically treated wiping clothes and mops which do not just "push dirt around" but actually pick it up. 0 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 the application of the dust control item. As in the case of uniforms, the dust control items may either be provided on a rental basis or be owned by the customer. Industrial launderers with drycleaning facilities constitute about 42.5 percent of the total number of establishments.3 About 27 percent of the total weight of uniforms, dust control items, etc., is drycleaned using either perc or Stoddard.6 Fifty percent of drycleaning is based on perc, the balance using Stoddard-sol- vent. However, on the basis of number of machines the breakdown is 60 and 40 percent respectively. While industrial drycleaning operations vary in number and size of machines, typical industrial systems are transfer types and consist of a 113 kg (250 lb) washer/extractor and a matching dryer/reclaimer as previously described in Section 2.1.2.3 Multibath washing in which items to be cleaned are subjected to a water and detergent wash, a solvent wash, and a solvent rinse, is common. Solvent filtration is seldom used.8 Suspended matter and NVR are removed by distillation. The residue from distilla- tion is further cooked down to remove solvent in a muck cooker. A typical industrial drycleaning operation will process 470,000 kg (1,036,000 lb) of uniforms, etc., per year. A typical industrial drycleaning operation is schematically shown in Figure 2-2. The system consists of a washer/extractor, dryer, carbon adsorber, a distillation unit, and muck cooker. 10 ------- t MAKE-UP SOLUTION Figure 2-2. Flow diagram of industrial drycleaning operation. ------- The plant handles 240,000 to 700,000 kg (600,000 to 1,500,000 lb) 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 while pants are only cleaned using two perc baths. The reason for using a water bath on shirts is to remove water solubles (caked dirt and perspiration). The perc washing and drying steps are similar to those for 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. Steam is used as the heat source. The oil that accumu- lates in the still is pumped to the muck cooker at the end of the day. Here live steam is directly injected into the oil solvent mixture (steam distillation) in addition to indirect steam as a source of heat. The distillation is continued until a sharp rise in the outlet condenser cooling water temperature 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 cooling water flow to the condenser remains constant, an increase in the outlet temperature of the cooling water is observed. The condensed solvent/water mixture is sent to a separator from which reclaimed solvent is sent to the still feed tank. A heavy black residue remains in the still which must be disposed of. The vents from all solvent tanks, the still, and the muck cooker are manifolded 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 through a bed of salt (baker's salt). To minimize solvent loss in dual-phase opera- tions, the washer/extractor and drains are flushed with a minimal amount of water. This solvent is separated in a two-stage pro- cess . 12 ------- 2.2 DEMOGRAPHY OF ESTABLISHMENTS IN THE COIN-OPERATED, COMMERCIAL AND INDUSTRIAL SECTORS Data on the distribution of the drycleaning establishments by State, U.S. Environmental Protection Agency (EPA) Region, and nonattainment area were obtained from County Business Patterns (CBP) 1976 which is an annual Bureau of Census (BOC) Publication.9 The detailed information is contained in the Appendix to this report. The data compiled and reported include total number of establishments in each industry (SIC codes 7215, 7216, and 7218), in each county, and in each state plus the District of Columbia. Data on independent cities (such as Baltimore, Maryland) that do not lie within counties are also given. A listing of the indepen- dent cities within each state is given in the Worldwide Geographi- cal Location Codes publication.10 CBP data 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 given in the following table: Employment-size class Number of employees 1 1 to 4 2 5 to 9 3 10 to 19 4 20 to 49 5 50 to 99 6 100 to 249 7 250 to 499 8 500 to 999 10 1000 or more Before pertinent demographic data are presented, background information on the sources of data in CBP will be discussed. This will be helpful in determining the limitations associated with using the data for estimation of potential emissions and identification of problem areas. Data for the 1976 CBP are extracted from the BOC Standard Statistical Establishment List (SSEL). The latter is updated annually by BOC on the basis of information obtained by the 13 ------- Internal Revenue Service (IRS), the Social Security Administra- tion (SSA), and the BOC data files. Employment information for single establishment employers (or one-location employers) is obtained from SSA 1976 first quarter Form 941 Schedule A. Employ- ment information for multiestablishment (multilocation) employers is extracted from 1975 and 1976 Annual Organization Surveys conducted by BOC. Each legal entity (corporation, partnership, single proprie- torship, etc.) having paid employees is required to file a separ- ate Employers' Quarterly Federal Tax Return, Treasury Form 941, identified by an employer identification number. In case of single location legal entities, each fourth quarter 941 report is counted as an establishment. For legal entities comprised of more than one location each location is counted as one establish- ment if it was determined to be in active' status as of December 15, 1976. The determination is made on the basis of information obtained from the 1976 Annual Company Organization Survey. Industry Classifications are based on the 1972 Edition of the Standard Industrial Classification Manual.1 The SIC of an establishment is based on the principal product or group of products produced or distributed, or by the principal services rendered by the establishment. Principle means that the estab- lishment derives 50 percent or more of its revenue from activities (or services rendered) defined by the SIC code. This is the so-called "50 percent rule." Data are not shown separately for any SIC that does not have at least 50 employees in the county, State, or United States. However, data on such establishments are reported under the totals for the industry group. For example, if the total employment in all commercial drycleaning establish- ments (SIC 7216) in one county is less than 50, these establish- ments are not reported under SIC 7216. They are reported, however, with the county totals for the major industry group 721. CBP data on the coin-op, commercial, and industrial launder- ers located in each EPA region and nonattainment areas are summa- rized in Tables 2-1, 2-2, and 2-3 respectively. 14 ------- TABLE 2-1. SUMMARY LIST - COIN-OPERATED LAUNDRIES AND DRYCLEANERS IN THE U.S., 1976 Reqi on Total coin-ops Coin-ops in attainment areas Coin-ops in nonattainment 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 IX 816 421 395 X 363 264 99 Total 11804 6080 5724 15 ------- TABLE 2-2. SUMMARY LIST - COMMERCIAL DRYCLEANERS IN THE U.S., 1976 Reqion Total commercials Commercials in attainment areas Commercials in nonattainment areas I 1092 72 1020 II 2920 0 2920 III 2115 501 1614 IV 3664 2255 1409 V 3680 1050 2630 VI 2292 1154 1138 VII 1000 631 369 VIII 579 274 305 IX 2049 590 1459 X 562 277 285 .Total 19953 6804 13149 16 ------- TABLE 2-3. SUMMARY LIST - INDUSTRIAL LAUNDRIES AND DRYCLEANERS IN THE U.S., 1976 Region Total industrials Industrials in . attainment areas Industrials in nonattainment 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 17 ------- 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 Council (NALCC).11 This 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).3 Since more than 50 percent of the company's 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 and may thus have no employees. The totals for the commercial and industrial sector are more likely to be accurate. Nonattainment counties, cities, etc. with respect to photo- chemical oxidants for each state were obtained from a recent PEDCo compilation based on information contained in recent issues of the Federal Register.12 Where the states reported nonattainment on the basis of Air Quality Control Regions (AQCR), or parts thereof, within the state, the Federal Air Quality Control Regions Manual13 was used to obtain a listing of counties within the AQCR(s). For counties which only partially lie within a given AQCR, the whole county was assumed to be nonattainment for purposes of this compilation. The number of establishments in attainment areas for all three sectors were obtained as differences between the counts for state and 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. Percentage breakdowns of the totals for these regions are as follows: coin-ops, 76 percent; commercials, 74 percent; and industrials, 73 percent. The industry percentages located in nonattainment areas are as follows: coin-ops, 48 percent; commercials, 66 per- cent; and industrials, 62 percent. 2.3 POTENTIAL EMISSIONS Perc emission factors express the amount of perc used to clean a given weight of clothing. The smallest emission factor 18 ------- indicates the most efficient plant. Emission factors may be expressed in terms of individual emission sources or as an overall plant emission. These emission factors are usually reported as kilograms of solvent per 100 kilograms of clothing cleaned. When applied to the solvent loss from the overall plant operation it is referred to in the industry as "mileage." In the following sections, a discussion of the sources of perc emissions and the associated emission factors will be given. Also total emissions based on these emission factors will be estimated for each state, for each EPA region, and for each nonattainment and attainment area within each state. 2.3.1 Sources of Perc Emissions and Emission Factors In the typical coin-operated establishment with drycleaning facilities there are two 3.6 kg (8 lb) dry-to-dry perc dryclean- ing units. A typical coin-op processes approximately 9,050 kg (20,000 lb) of clothes per year.3 Emissions of perc from the typical coin-op include evaporation losses during aeration or deodorization of the clothes, filter disposal, and miscellaneous losses, primarily leaks. A properly maintained and operated dry-to-dry coin-op dry- cleaning unit will vent to the atmosphere only during the deodor- ization cycle. After drying, and before aeration, the clothes contain approximately 3 to 6 percent perc by weight if the unit is operated properly. Clothes contain 20 to 25 percent perc by weight after washing and extraction. If the unit is not operated properly, the clothes can contain more than 3 to 6 percent and excessive perc emissions will occur during the deodorization cycle. Cartridge filters were originally introduced to the dryclean- ing industry on the coin-op machines. Coin-ops predominantly use this type of filter because it is a multicharge filter. A car- tridge filter will average 60 to 65 loads of clothes for a 3.6 kg (8 lb) capacity machine.14 According to the CTG, cartridge filters are confined and contained which inherently reduce the 19 ------- perc emissions to 1 kg of perc per 100 kg of clothes cleaned (corresponds to 1 percent perc by weight).15 Presently, 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 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 factor for the higher emissions from the coin-operated drycleaner is that it takes five loads of clothes in the 3.6 kg (8 lb) capacity unit to equal the weight of clothes processed in one load in a similar 18 kg (40 lb) capacity unit used in a commercial or industrial application. Since there are "fixed" solvent losses for each washing/drying cycle, 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 charg- ing and discharging operations. 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. An emission factor of 35.1 kg perc per 100 kg clothes processed (2000 lb of clothes per drum of solvent) based on a range of values reported in an EPA report16 was used for the coin-operated drycleaners. For commercial drycleaners the aeration step is a major source of perc vapors to the atmosphere when carbon adsorbers are not used. Other sources of perc emissions are: transfer opera- tions, evaporation losses at the washer and dryer, distillation unit, losses from pumps, valves, flanges, seals, water separa- tors, and inefficiencies in handling solvent. In addition, 20 ------- significant losses of liquid perc occur in the disposal of distil- lation and muck cooker residues and filter cartridges. Plant emission factors derived from Dallas and Hamilton County surveys (details in Section 4) include all plants with and without carbon adsorbers and are given in the following table. REPRESENTATIVE EMISSION FACTORS FOR COMMERCIAL DRYCLEANERS Employment- size class Emission factors, kg perc/100 kg clothing Dallas County Hamilton County Combined 1-4 employees 19.8 (31)a 22.1 (46) 21.5 (77) 5-9 employees 14 (35) 19.4 (17) 15.8 (52) 10-19 employees 10.2 (9) 22.7 (8) 16.1 (17) >20 employees 11.8 (2) 15.6 (1) 13.1 (3) All " 16.2 (77) 21.4 (72) 18.7 (149) Numbers in parentheses are the number of plants surveyed in each employment-size class. The emission factors above are arithmetic averages of the Dallas and Hamilton County surveys. A linear regression was performed on the data points; however the correlation factors ranged from below 10 percent to about 50 percent for the various employment-size classes. A correlation factor of at least 80 per- cent would be necessary before assuming a linear fit of the data. The weights of clothing cleaned in each employment-size class shown in the next table are the results of the Dallas and Hamilton County surveys (Section 4). The numbers shown are arithmetic averages of the reported amounts of clothing cleaned. These numbers can be compared to the 17,700 kg/yr (39,021 lb/yr) clothing cleaned by a typical drycleaner, from a survey conducted by the International Fabricare Institute (IFI) in 1975.16 A model plant was designated for the commercial drycleaners in the New Source Performance Standards (NSPS) Background Document which showed 28,175 kg/yr (62,115 lb/yr) clothing cleaned.3 21 ------- REPRESENTATIVE WEIGHTS OF CLOTHING CLEANED BY COMMERCIAL DRYCLEANERS Employment- size class Clothina cleaned, kg/yr Dallas Hamilton Combined 1-4 employees 5-9 employees 10-19 employees >20 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. The results of the Dallas and Hamilton County surveys con- ducted in 1979 are significantly higher tfran earlier surveys. This appears to reflect the expected increase in demand for dry- cleaning services as discussed in the NSPS Background Document.3 While dry-to-dry machines are used exclusively by the coin-ops and while they account for only 2.5 percent of drycleaning machines in the commercial sector, transfer type operations are predominant in the industrial drycleaning plants. This is especially true of the larger systems equal to or larger than 113 kg (250 lb) in size. Dry-to-dry machines are, however, receiving larger accept- ance by the industrials because these minimize worker exposure to perc fumes by eliminating the necessity for transferring cleaned items from washer to dryer. The sources of emissions from industrial drycleaning systems are as follows: ° Improperly vented equipment ° Solvent retained in distillation residues ° Miscellaneous liquid and vapor leaks caused by lack of proper maintenance ° Accidental losses and discharges of solvents 22 ------- Excess emissions take place when point sources within the system are not properly vented to a carbon adsorption system. These are as follows: ° 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 pick-up points such as the washer/ extractor door In tests conducted on behalf of EPA, losses from these point sources totalled 7 kg per 100 kg clothes (7 lb per 100 lb clothes) in the absence of a carbon adsorber.4 With carbon adsorption these losses may be reduced to 0.3 kg per 100 kg clothes. Solvent retained in distillation residues is a potential source of emissions in case of improper disposal into open dumps using containers that are prone to corrosion or are easily punc- tured in handling operations by refuse transportation vehicles and/or earth-moving equipment at the disposal site. Most industrial drycleaners do not practice solvent filtra- tion as a means of solvent purification.8 Distillation is used as a means of solvent purification. Suspended matter and NVR are retained in the still residue. In tests conducted by IFI, the emissions from this source were estimated at 1.6 kg perc per 100 kg clothes (1.6 lb perc per 100 lb clothes).4 Miscellaneous losses are usually in the form of liquid and vapor leaks. Liquid leaks may take place because of: ° Defective gaskets on washing machine doors and button traps 0 Defective seals on pumps, valves, and pipe fittings Vapor leaks may occur because of: 0 Defective gaskets on dampers used in isolating the air recirculated during drying ° Torn, punctured, or damaged air ducts to and from the dryer 23 ------- These miscellaneous losses have been estimated at 2 kg and 1 kg per 100 kg clothes by IFI and EPA, respectively. The emission factors reported above for industrial operations are for well-operated systems. The total emissions factor for systems without carbon adsorbers is 10.6 kg per 100 kg clothes while that for systems with carbon adsorbers is 3.9 kg per 100 kg clothes. The latter value for well-operated sytems has been substan- tiated in source field measurements and reported for others.17'18'19'20'21 At an industrial operation with a 136 kg (300 lb) machine, tests conducted on behalf of EPA showed an emission factor of 2.35 kg per 100 kg clothes (2.35 lb per 100 lb).17'21 Another industrial facility with two 113 kg (250 lb) machines reports an emission factor of 4.5 kg per 100 kg clothes.19 It is reported that 50 percent of all industrial drycleaning systems are fitted with carbon adsorption control devices.3 This yields a weighted emission factor of 7.25 kg per 100 kg clothes for well-operated systems. However, the fraction of systems that are well-operated is not known. Data on four industrial drycleaning operations obtained from the survey of Dallas County have shown that solvent consumption is higher than 7.25 kg per 100 kg (7.25 lb per 100 lb). Solvent loss in these plants averaged 15 kg per 100 kg clothes (15 lb per 100 lb). Emission factors and assumptions used in calculating total perc emissions are summarized in Table 2-4. 2.3.2 Total Emissions On the basis of the emission factors presented in the last section and representative weights of clothing cleaned per estab- lishment, total perc emissions may be estimated. Table 2-5 provides a summary of these emissions by EPA region and non- attainment areas within each region. From the table, it is apparent that the majority of perc emissions are found in the more densely populated areas. EPA 24 ------- TABLE 2-4. SUMMARY OF EMISSION FACTORS AND WEIGHT OF CLOTHING CLEANED PER ESTABLISHMENT. Coi n-0p Commerci al Industri al Emission factor, kg perc per 100 kg clothes cleaned All Plants 1-4 employees 5-9 employees 10-19 employees ^20 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 s?20 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 25 ------- TABLE 2-5. SUMMARY LIST - 1976 EMISSIONS FROM PERC DRYCLEANERS, METRIC TONS Perc emission from roin-ODPrated drvcleaners Perc emissions from commercial drvcleaners Perc emissions from industrial drycleaners Regi on Total 1 Nonattainment areas Total Nonattainment areas Total Nonattainment areas I 777.6 599. 3 5,508.7 5,163.3 599.4 569.4 II 1,648.7 1 ,648.7 13,817.7 13,817.7 1 ,363.3 1,363.3 III 1,535.7 850. 1 11,102.3 8,525.6 1,243.5 824.0 IV 3,195.7 940.8 18,763.4 7,513.4 2,726.6 1 ,273.6 V 4,072.5 2,060.0 18,797.8 13,808.1 2,876.4 1,872.7 VI 2,103.1 885. 1 11,563.2 6,113.1 1,677.8 883.9 VII 971.4 193.7 4,895.3 1,941.9 794. 1 194.8 VIII 503.0 111.5 2,870.7 1,535.0 209.7 89.9 IX 1 ,137.3 550.5 10,307.4 7,430. 1 1,767.8 1 ,213.5 X 505.9 138.0 2,688.6 1,371.2 314.6 89.9 Total 16,450.9 7,977.7 100,315. 1 67,219.4 13,573.2 8,375.0 ------- Regions 2 through 6 account for 74 percent of the perc emissions from drycleaners. Nonattainment areas account for 64 percent of the perc emissions from drycleaners. Nationwide total perc emissions based on the number of drycleaning establishments from the 1976 CBP publication are 130.000 metric ton (143,000 ton). Sources in industry indicate that the perc consumption is closer to 158,000 metric ton (174,000 ton). In a recent IFI newsletter, 15,000 coin-ops using perc were estimated. This is almost three times that estimated by CBP. Assuming the number of coin-ops is twice that reported by CBP, total 1976 perc emissions would be 146,000 metric ton (161,000 ton). This figure is within ten percent of the reported consumption; the assumption that the number of coin-op plants is twice that reported in CBP will be used in the following sections. 2.4 GROWTH PATTERNS 2.4.1 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 which operate drycleaning units. CBP data for 1976 showed that the number of coin-ops were 11,804. Assuming that the actual number of coin-ops is 23,608 and that the expected population growth rate is 0.9 per- cent3 the number of coin-operated plants can be estimated for 1979, 1980, 1985, and 1990. GROWTH PATTERNS FOR THE C0IN-0P SECTOR DURING THE 1980'S Year No. of Coin-ops 1976 1979 1980 1985 1990 23,608 24,251 24,469 25,591 26,763 27 ------- 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 perc fumes when burned in the combustion air for the laundromat dryers will produce a green residue on the burners. This results in inefficient dryers and higher maintenance cost. Presently, 97.5 percent of the coin-op drycleaning operations use perc as the drycleaning solvent. Most of the industry sources agree that perc will continue to be the predominant solvent used by the coin-ops. Classification of perc as a carcinogen or hazardous pollutant may reverse the role of perc in the entire drycleaning industry. Closed systems using perc as a drycleaning solvent would be a viable alternative if this occurs. However, other solvents which are believed to be nonphotochemically reac- tive, such as Freon (F-113), could be used in place of perc. There is some indication that fluorocarbons such as F-113 may cause depletion of the upper atmospheric ozone layer. 2.4.2 Growth Patterns for Commercial Drycleaners Historically, the number of commercial drycleaning establish- ments declined from 1967 through 1976.3 This occurred during a period of time when synthetic, washable fabrics were becoming more popular. Also the demand for drycleaning services decreases during times of adverse economic conditions as occurred in 1974 and 1975. During that period the trend was toward fewer, larger establishments with larger machines. In the past several years there has been a change in clothing styles to using more natural fabrics which is expected to increase the demand for drycleaning in both the commercial and coin-oper- ated sectors.3 There is no evidence to suggest whether switching would occur from the commercial type drycleaning to the less expensive coin-operated type, if a recession should occur. Industry sources indicate that switching is unlikely, and there should be a gradual increase in demand for both sectors during 28 ------- the next five to ten years. This increase in demand is expected to be about equal to population growth which would be about 0.9 percent per year according to work conducted on behalf of the EPA. 3 Using the number of establishments in 1976 as the base number, a growth factor of 0.9 percent per year was applied, resulting in the increase in number of establishments given in the following table. 2.4.3 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 1976.3 While this sector is also affected by general economic trends, annual growth rates GROWTH PATTERNS FOR THE . COMMERCIAL SECTOR DURING THE 19801 S Year No. of establishments 1976 19,953 1979 20,497 1980 20,681 1985 21,629 1990 22,620 (both negative and positive) in number of establishments have historically been of the order of few percentage points. Since no general economic downturn took place between the present time and 1976, a positive growth may be assumed during that period. Industry sources indicate that growth in weight of articles cleaned (both laundry and drycleaning) by the industrial sector usually parallels the growth in population.7'8' In a recent study for EPA, the population growth rate in the period 1977 to 1985 has been reported at 0.9 percent per year. For purposes of this study this will be used to predict the total number of industrial drycleaning sources in 1979, 1980, 1985, and 1990. 29 ------- GROWTH PATTERNS FOR THE INDUSTRIAL SECTOR DURING THE 1980'S Year No. of establishments 1976 1979 1980 1985 1990 906 931 939 982 1027 During the past several years a large growth in perc dryclean- ing at the expense of water and detergent-based laundering was anticipated. This was caused by the enactment of water pollution regulations affecting the use of detergents.7 This, in addition to rising sewerage rates levied by municipalities on the basis of total water used, enhanced the prospects of perc as a replacement for water washing of some articles. Current OSHA regulations, limiting worker exposure to a total weighted average concentrat- ion of 100 ppm perc in the work environment and upcoming regula- tion of perc emissions from new and existing sources by EPA, have detracted from the anticipated switching to perc. Additionally, EPA has determined that perc may be a carcinogen. If this is confirmed the future use of perc may be restricted. All these factors tend to create uncertainties in predicting future use. No switching to petroleum solvents is anticipated for new sources because of their higher cost and fire hazards. Existing perc systems are expected to be replaced by similar, but perhaps larger, perc-based systems. Therefore, the current estimate that 50 percent of all drycleaning is carried out using perc, is expected to hold throughout the time frame under consideration. 2.4.2 Perc Emission Projections Current annual consumption of perc is reported at 158,000 metric ton (174,000 ton). Using the number of drycleaning estab- lishments obtained from the CBP publication and assuming the number of coin-ops is twice that reported, the 1976 perc emissions 30 ------- were 146,000 metric ton (161,000 ton). This latter figure will be used in the emission projections. Until application of RACT, perc emissions will increase in the three industry sectors with 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 maintenance 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. After application of RACT is complete, perc emissions will then increase with population growth. In the CTG and proposed standards background documents, uncontrolled and controlled emission factors were given for the three industry sectors. This report indicates that the uncontrol- led emission factors are considerably higher. Hence, it is anticipated that the controlled emission factors will also be higher. Table 2-6 presents the emissions factors from the CTG and NSPS background document and those predicted from this study. The emission factors reported in the CTG and NSPS background document were obtained from three carefully controlled emission tests. It is our opinion that actual operations will not attain these low emission factors; however, the same emission reduction percentage for each sector is probably achievable with application of RACT. The perc emission projections for 1980, 1985, and 1990 are presented using both sets of data for the controlled emission factors. PERC EMISSION PROJECTIONS, METRIC TONS Year CTG emission projections PEDCo emission projections 1976 1980 1985 1990 146,800 152,200 50,500 52,900 146,800 152,200 80,200 83,900 31 ------- TABLE 2-6. PERC EMISSION FACTORS BEFORE AND AFTER APPLICATION OF RACT, kg/100 kg OF CLOTHES CTG emission factors3'^ Q PEDCo emission factors Industry Sector Uncontrolled Controlled Uncontrolled Controlled Coi n-op 20 15 35.1 26.3 Commerical 12 5 18.7 7.8 Industrial 12 5 15 6.2 Control of Volatile Organic Emissions from Perchloroethylene Drycleaning Systems. U.S. Environmental Protection Agency. Research Triangle Park, North Carolina. EPA-450/2-78-050. December 1978. p. 5-2 and 5-3. ^Perchloroethylene Drycleaning - Background Information for Proposed Standards. U.S. Environmental Protection Agency. Research Triangle Park, North Carolina. EPA-450/3-79-029a. August 1979. p. 6-7. c Controlled emission factors were obtained by multiplying PEDCo1s uncontrolled emission factors by percentage reduction achieved with EPA estimates for each industry sector. 32 ------- SECTION 3 CONTROL TECHNOLOGY AND FACTORS AFFECTING ITS ENFORCEMENT In December 1978, a CTG was issued by the EPA's Office of Air Quality Planning and Standards which specified means of controlling perc emissions from drycleaning systems in the coin-op, commercial, and industrial sectors. Regulations based on reason- ably available control technology are currently being formulated. A brief description of RACT and factors affecting its enforcement will be .discussed in the following paragraphs for the coin-oper- ated, commercial, and industrial sectors. 3.1 SUMMARY OF REGULATIONS On the basis of the control technology specified in the CTG document,4 regulations affecting existing sources of emissions of perc from the three sectors of concern will be issued in the very near future. A summary of these expected regulations is given in the following paragraphs. 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 functioning 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; 33 ------- ° Reduce the volatile organic compounds from all solvent stills to 60 kg or less per 100 kg of wet waste material; ° 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 atmo- sphere . For systems where solvent purification by distillation, muck cooking, and filtration is not carried out, the owner/operator must restrict wastes losses resulting from solvent purification to 1 kg per 100 kg clothes processed (1 lb per 100 lb). Demon- stration of these loss limits is also reguired. A number of dry cleaning systems will be exempted from the provisions pertaining to carbon adsorption and the associated 100 ppm emission limit. These systems are: 0 Coin-operated dry cleaning systems. ° Other systems where space limitations prevent the installation of a carbon adsorber and/or systems where steam required 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 components found to be leaking will be determined by visual inspection. Specifically the following com- ponents are included in this item covering liquid leaks. These are: 00 Hose connections, couplings, and valves. 00 Machine door gaskets and seatings. 00 Filter head gaskets and seatings. ° ° Pumps. 00 Base tanks and storage containers. 00 Water separators. 34 ------- 00 Filter sludge recovery. 00 Distillation unit. 00 Diverter valves. 00 Saturated lint from lint basket. 00 Cartridge filters. Compliance with the 100 ppm emission standard will be deter- mined by: 0 Tests methods outlined in EPA Guideline Series document, "Measurement of Volatile Organic Compounds," EPA 450/2-78-041 .'22 0 The proper installation, operation, and maintenance of equipment which 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 (ANSI) standard procedure for determination of "Dilution of Gasoline Engine Crankcase Oils." 3.2 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR PERCHLOROETHYLENE DRYCLEANING SYSTEMS The regulations of perc emissions from drycleaning systems presented in the last section are based on control techniques specified in the CTG document.4 Briefly these techniques specify the use of activated carbon adsorption for control of emissions from air streams containing perc vapor and the implementation of good housekeeping and equipment maintenance practices to control fugitive emissions, liquid leaks and miscellaneous losses. As mentioned earlier coin-operated systems have been exempted from the use of activated carbon adsorption because of the lack of availability of steam to desorb the carbon bed and/or the lack of space necessary for the installation of the 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 carried 35 ------- out on such systems, carbon bed inlet concentrations ranged from 540 to 6500 ppm.19,20'21 Removal efficiencies were usually equal to or better than 95 percent 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 lignite, peat, and wood) and subsequent activation. The carbon- ization process produces a spongelike structure with a large internal surface area (500 to 1000 m2/g) The pores within the structure have sizes of the order of the molecules to be adsorbed These pores are not uniform in size and are thought to consist of voids between crystallites of carbon formed during carbonization. Activation of the carbonized material consists of passing steam and/or air at high temperatures to effect oxidation and removal of strongly adsorbed hydrocarbons between the aforementioned crystallites. This exposes more surface area for adsorption of the desired species. The crystallites exert an attractive force on the species of interest when it comes into contact with them.2 Beds of activated carbon suitable for use in adsorption of perchloroethylene vapors from drycleaning operations are designed according to the following criteria:24 0 Space velocities of the order of 0.01 minutes. Space velocity is defined as the ratio of volumet- ric flow of treated gas to volume of bed. 0 A ratio of volumetric flow rate to bed cross-sec- tional area of about 328 m per minute per m2 of cross sectional area (100 ft per minute per ft2). 0 A bed working capacity of about 20 percent. That is the weight of perchloroethylene 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 inches) As a rule-of-thumb, the volumetric gas flow vented to the carbon bed during aeration is usually of the order of 0.25 dry standard cubic meters per minute per kg of clothes dried (4 dscfm per lb clothes). Temperatures of the bed inlet and outlet gas are of ------- the order of 43°C and 24°C (110°F and 75°F) respectively. Moisture contents of the order of 1 percent are usual.19'20'21 The adsorbed perc may be desorbed using 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. These sources are: ° washer/extracter vents ° solvent tank vents ° floor pick-up points ° vents from distillation units and muck cookers ° water separator vents ° air from the deodorization (or aeration) step. Good housekeeping and maintenance practices are required by the regulations for all three sectors of .the perc dry cleaning industry. Two types of perc losses are defined.4 The first type pertains to "point" losses while the second is concerned with "fugitive" losses. In the following discussion, these sources will be enumerated and comments about their proper maintenance will be made. These losses may be either in vapor or liquid form. Losses caused by liquid leaks are relatively easy to detect by visual inspection of piping and fittings and solvent storage vessels. Vapor leaks are more difficult to detect but can be detected by smell (at 50 to 200 ppm level), by use of soap solu- tion 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.4'25 Required inspection and/or maintenance procedures to be performed are briefly dis- cussed: ° Hose Connections, 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. 37 ------- ° Machine Door Gaskets and Seating: During the wash cycle an ill-fitting or damaged cleaning machine door gasket will cause solvent to leak. This would occur if the gasket is old and needs replace- ment. 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, the gaskets become damaged. This is especially true of paper cartridge filters which require periodic replacement. 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. ° Base Tanks and Solvent Storage Tanks: These should be properly vented to either water-cooled condensers or preferably to carbon adsorbers to prevent vapor leaks. Corrosion of tanks and fittings may lead to liquid leaks. ° Water Separators: Solvent loss in water separators may occur m the water layer as a result of a lint-clogged vent or corrosion in the line leading to the solvent tank. These may result in liquid leaks and solvent loss. ° 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 oil.26 ° Distillation Unit: The distillation unit should be properly operated and vented to a condenser or the activated carbon adsorption unit to prevent vapor leaks. The unit must be operated and main- tained 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 on a daily basis. ° Cartridge Filters: Spent cartridge filters should be drained for 24 hours before disposal. This is 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 lint-clogged 38 ------- lint bag (used in removing lint from recirculating air during drying) will reduce the air flow and the amount of solvent re- covered. The lint should be removed twice daily. The lint bags should also be drycleaned twice a month to remove grease buildup which tends to mat the lint resulting in undue resistance to air flow. Lint buildup on condenser and heating units will reduce the cooling and heating capacities of these units. Solvent recovery during the drying phase will thus be reduced. Conse- quently, more perc will be vented during aeration, and more will be retained in the clothes. These units should be inspected, and lint buildup removed at least once every six months. Lint may accumulate at air inlet and outlet valves (dampers), preventing them from seating properly during the drying cycle. Vapor losses will result. 3.3 FACTORS AFFECTING ENFORCEMENT OF REGULATIONS The CTG document in which RACT is specified 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 prom- ulgated regulations have additionally allowed the use of "equally effective control devices." While such equally effective control devices have not been described in the CTG document, some of these will be mentioned here in order to aid EPA in future inves- tigations of their effectiveness. These systems utilize refriger- ation 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/distrib- utors of these refrigeration systems are: ° Spencer America Corporation, St. Louis, Missouri 0 Kleen-Rite, Inc., St. Louis, Missouri It must be emphasized that, in contrast to carbon adsorption systems, the air is recirculated during aeration in refrigeration systems. In adsorption systems fresh air (once-through) is blown 39 ------- through the clothes. This apparently renders carbon adsorption technically more versatile, especially for transfer systems, than refrigeration since it is feasible to use the adsorber in recovery of perc from vents, distillation units, floor pick-up points, etc. Refrigeration systems may conceptually be used in these applications. But the technical and economic feasibility in these extended applications are to be determined. Perc concentrations in the air vented during aeration through activated carbon systems have consistently been much lower than 100 ppm in well operated systems.17'19'20'21 The regulations specify a 100 ppm limit since it is ample indication of break- through to enforcement officials. While accur-ate methods for determination of perc at the specified concentration are available, there are apparently no relatively inexpensive devices available for determination of continuous compliance with the standard. EPA is currently involved in the development of a reference method for determination of perc in the concentration range(s) of interest. The availability and cost of such a device are vital to any future compliance monitoring activities. It should be emphasized that currently available methods, involving the use of gas chromatography (GC) techniques, are technically adequate for determination of initial and continuous compliance with the 100 ppm standard. The costs of operating such a monitoring device,.however, are burdensome to industrial and commercial establishments. Furthermore, these establishments are not likely to hire personnel or already to have employees capable of cali- brating, operating, and maintaining such detection devices. For purposes of enforcement, it may be feasible to establish relatively simple "indicators" which enforcement officials can use to deter- mine whether or not the adsorbers in question are effective in removing perc vapors. Such indicators would be the observation of the weight (or volume) of perc obtained after each desorption of the carbon bed, for example. 40 ------- This is an indicator only when all key maintenance and good housekeeping items have been met. For example, the volume of perc obtained after each desorb is not an indicator if the air inlet and outlet dampers do not seat properly because of defec- tive gaskets and/or lint accumulation. The regulations call for the immediate repair of all system components found to be leaking liquid perc. This is generally easier for industrial sources to comply with than commercial ones. The larger industrial establishments usually employ per- sonnel who are trained in the maintenance of the drycleaning system. Commercial drycleaning systems are less likely to be operated by personnel who are familiar with all aspects of good housekeeping and maintenance practices, and since they are usually involved in system operation (rather than maintenance), they are more likely to emphasize "production" rather than maintenance. The allowable perc contents in the residues from muck cook- ing and distillation operations are 25 and 60 kg perc per 100 kg of wet waste material, respectively. While relatively few data are available on the perc separation and recovery capabilities of muck cookers and distillation units, actual data taken on behalf of EPA indicate that much lower perc contents in the residues from these units are possible in well-operated systems. Perc contents of the order of a few percent were reported.17 Perc is a potentially hazardous substance. Effort should be made to minimize its release to the environment. The regulations do not comment on the residual amount of perc contained in the carbon from the carbon adsorber should it ever be 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). This implies 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 anticipated that the average life of the activated carbon is 3 to 5 years. It may be necessary to require 41 ------- disposal of the carbon in sealed containers to avoid subsequent release to the atmosphere. The regulations require the draining of all filtration cartridges in their housing for at least 24 hours to minimize their perc contents. Where multi-element solvent filtration systems are available (as is probably the case in commercial establishments) draining of spent cartridges for 24 hours is feasible. However coin-operated filtration systems are usually single-element. The 24-hour requirement may thus be a hardship to coin-operated establishments. A double-bucket device with a lid may serve the purpose of draining the filter cartridges. Further removal of perc from the cartridges may be effected by drying with hot air in an oven-type device which is currently marketed for this purpose. It is also feasible to use the drying tumbler to effect drying of the cartridges by holding the wheel stationary. The regulations do not specifically require the drying of cartridges. This is left to the discretion of the operator. From the point of view of enforcement, the regulations pertaining to 1) the use of a properly functioning carbon adsorber, 2) limiting 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 may present difficulties to enforcement officials. The first two items present difficulties in enforcement in the absence of a relatively inexpensive continu- ous monitor of perc in the concentration range of 10 to 200 ppm and/or a control equipment adequacy demonstration program. The last two items present difficulties in that they require enforce- ment officials to spend more time on system inspection to identify leaky components and to make sure that filtration cartridges are drained for 24 hours. This 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 solvent consump- tion rate (or mileage standard) for establishments in all three 42 ------- sectors. For industrial and commercial establishments the stan- dards for solvent consumption rate will be based on data obtained for well-operated systems with carbon adsorbers. These rates obtained from the CTG are expected to be in the range of 2 to 5 kg perc per 100 kg clothes; however, this report indicates that the well-operated plant emission rates 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 perc consumed per 10 (or 100) cleaning cycles that the machine is subjected to. For commercial and industrial establishments the reporting require- ments for 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 requirements would be the same except for weight of clothing. The total number of cycles (based on total receipts) should be reported. The reported data on solvent consumption may be verified by obtaining sales information from solvent manufacturers and distri- butors. Data on weight of clothing drycleaned may be verified by estimating the number of loads run based on machine capacity. This may not be accurate but approximate agreement with the reported value of clothes processed will enhance the credibility of the latter. In discussions with officials from the South Coast Air Quality Management District in Los Angeles, California, they indicated they would prefer a regulation based on mileage criteria. However, they were told by the California Air Resources Board that such a regulation is unenforceable because it is illegal to use a person's records to cite him for a violation. The legality of using personal records to enforce mileage criteria should be investigated. The regulation also exempts facilities from installing carbon adsorbers or equivalent technology that are coin-operated, have space limitations, or have insufficient steam capacity to desorb the carbon adsorber. A more equitable approach may be to rank the drycleaning facilities into annual perc consumption 43 ------- ranges. All drycleaners below a certain annual consumption would be exempt from installing a carbon adsorber. A similar approach has been used in California for enactment of their petroleum solvent regulation. The advantages of this approach would be to zero in on the larger perc emission sources which have more impact on the overall perc emisisions and exempt the truly small operations whose owners can ill-afford the control device and are probably insignificant source of perc emissions. 44 ------- SECTION 4 METHODOLOGY OF IDENTIFICATION AND QUANTITATION OF EMISSION SOURCES 4.1 SOURCES OF INFORMATION After investigating a variety of data sources for demographic information on coin-operated, commercial, and industrial dryclean- ers, it was determined that a BOC report and the yellow pages provided the most useful and complete information. Trade associa- tions, government offices, and professional business listings were also contacted. The only government office having useful information on drycleaners for our study was BOC. Their CBP report was the most helpful. All drycleaners are required to report the number of employees they have to BOC on a yearly basis. The CBP report presents, for each county, the total number of people employed in a given industry (reported by the 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 U.S., the report was used in establishing the nationwide distribution of coin-operated, commer- cial, and industrial drycleaners. The CBP report does not provide names of drycleaning estab- lishments. Because a listing of drycleaners was necessary, the Texas Laundry and Dry Cleaning Association (TLDCA) was contacted as a potential source of information. Their information comes from the International Fabricare Institue (IFL) a trade associa- tion for drycleaners. IFI periodically provides the state asso- ciations with a list of drycleaners in that state. A copy of the IFI list is.not available for public use. Due to the rapid 45 ------- turnover rate in ownership of drycleaners, it is not possible for IFI or TLDCA to maintain an up-to-date list of drycleaners. Therefore, even if the list were available for public use, it would not be complete. Data companies such as R. L. Polk and National Business Lists who specialize in publishing lists of businesses were con- tacted as another potential source of information. The most complete lists of drycleaners found were from these two companies, both of which utilize the yellow pages in compiling their lists. These lists are helpful in that SIC codes are used to classify each business. National Business Lists stated that repetitive listings from the yellow pages are deleted from their lists, helping the user to avoid duplication in contacting the businesses. A principal disadvantage in using either the yellow pages or business lists derived from them is that not all drycleaners have telephones, particularly in the case of coin-operated cleaners, and not all drycleaners who have a telephone list their business in the yellow pages. 4.2 DALLAS AND HAMILTON COUNTIES SURVEYS In order to make a nationwide projection for the drycleaning industry, two metropolitan areas, Dallas County, Texas, and Hamilton County, Ohio, were studied in detail. The yellow pages for each of the areas were used as the source of names, addresses, and telephone numbers of drycleaners. Coin-operated cleaners were listed under "Cleaners-Self Service", and "Laundries-Self Service". Commercial drycleaners generally appeared under the heading "Cleaners" in the yellow pages. Duplicate listings for some stores could be found under "Hat Cleaners," "Leather Cleaning, 11 "Fur .Cleaning, 11 or "Laundries." Industrial cleaners are listed under "Uniform Rental," or in a few cases, "Tuxedo Rental." The cleaners in Dallas and Hamilton Counties listed under each of these headings were contacted by telephone and asked if 46 ------- they would supply some information for PEDCo's survey on dryclean- ers. Figure 4-1 is a copy of the data sheet which was used when contacting each drycleaner by telephone. From the information on the data sheet, perc consumption versus clothes cleaned (or mileage) rates can be determined. In assessing the preliminary responses to the survey, it was decided that questions dealing with sales and payroll figures would be deleted from the survey, as these questions generally evoked a negative reaction from the drycleaners. Additional questions were asked of those drycleaners which use perc and have a carbon adsorber. The survey of 129 coin-operated laundries and drycleaners resulted in 31 that do not have drycleaning equipment. Of the 98 installations which have drycleaning equipment, 17 percent definitely use perc. Fifty-four percent of the coin operators surveyed did not know or report the necessary information. This is primarily because the stores are often attended by persons who are not involved in purchasing perc or maintaining the machines. In some cases the store was unattended and a customer answered the telephone. Also, in a coin-operated facility it is generally not possible to maintain records of the weight of clothing dry- cleaned in a given time period. Of the drycleaners, two percent use freon as the solvent. Eight percent were out of business, 5 percent elected not to answer questions over the telephone, and 14 percent did not answer their telephone on several occasions; it is assumed these sources are unattended. Of the 581 commercial drycleaners which PEDCo attempted to contact, 5 percent were no longer in business. Another 17 per- cent of the commercial cleaners contacted refused to answer the survey questions over the telephone. Approximately, 21 percent of the commercial drycleaners contacted are pickup stations for other commercial drycleaning plants; in these cases the survey questions do not apply. Eighteen percent of the commercial drycleaners listed in the yellow pages used solvents other than perc. The remaining 39 percent of the commercial drycleaners use perc. Of the commercial drycleaners who use.perc, approximately 47 ------- Name: Telephone No.: Address: Manager/owner: County: SIC: Type of operation: Commercial Coin-operated Industrial Solvent used: Qty. of solvent used: gallons/day drums/month 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. week's/year Sales: Payroll: Comments: Figure 4-1. Orycleaning Industry Data Sheet. ------- 30 percent indicated that they are presently using a carbon adsorber in their plant; another 4 percent of the drycleaners said they plan to add a carbon adsorber. Industrial drycleaners showed a higher usage of carbon adsorbers. Fifty-six percent of the 16 industrial drycleaners contacted were found to use perc. Of these drycleaners, 67 per- cent have a carbon adsorber. The remaining 44 percent of the industrial drycleaners can be broken down as follows: 31 percent use solvents other than perc (naphtha) and 13 percent deal primar- ily in laundry services and send their drycleaning to a commercial drycleaner. Twenty-six commercial drycleaners in Dallas County which have a carbon adsorber were asked additional questions regarding the life of the carbon bed. The results of these inquiries are presented in Table 4.1. Five of the owners reported operating their adsorbers from 3 to 18 years without changing the carbon. Four owners reported changing the carbon every 1, 3, 5, and 10 years. Twelve owners said their adsorbers are less than 3 years old and have not changed the carbon. Five did not give the age of their adsorbers nor any indication of how often they change the carbon. None of the owners had tested their adsorbers to determine outlet concentrations of perc. In addition to contacting drycleaners over the telephone, several commercial plants were visited to verify data and gain knowledge of the drycleaning process. 4.3 RESULTS OF SURVEY Drycleaning establishments in Hamilton County, Ohio, and Dallas County, Texas, were surveyed by telephone to find out perc consumption, clothes processed, and number of employees. The results of the telephone survey for the commercial sector are contained in Tables 4-2 through 4-9. Four employment size classi- fications were obtained and the results tabulated for these categories. An arithmetic average of the emission rate (kg of 49 ------- TABLE 4-1. DALLAS COUNTY DRYCLEANERS USING CARBON ADSORBERS Manufacturer of adsorber Age of adsorber, yr. Frequency of carbon replacement Desorption schedule, times per week Basis of desorption schedule Hoyt <1 Never Dai ly Amount of perc recovered Hoyt NAa Never 2-3 Amount of clothes processed Vic 3 Never Dai ly Amount of perc recovered NAa 10 Once per year Dai ly NAa Hoyt <1 Never 3 Detection of perc by odor Hoyt <3 Never 2-3 Fogginess of filter gauge Vic >5 After 3 more years NAa NAa Hoyt <1 Never 2 Amount of clothes processed Hoyt 5 Never Dai ly Manufacturer's recommendation Hoyt NAa Never Dai ly Manufacturer's recommendati on Hoyt >5 After 5 years Dai ly Manufacturer's recommendati on Hoyt 4 Never Dai ly Manufacturer1s recommendation Hoyt <1 Never NAa NAa Hoyt <1 Never 1 Detection of perc odor Hoyt 1.5 Never 3 Amount of perc recovered Hoyt 1.5 Never 3 NAa Hoyt NAa NAa NAa NAa Hoyt 1-2 Never 2-3 Amount of clothes processed Hoyt 8 Never 3-5 Amount of clothes processed Vi c 1.5 Never Dai ly NAa Vic 1.8 Never 3 Amount of clothes processed 50 ------- TABLE 4-1. (continued) Manufacturer of adsorber Age of adsorber, yr. Frequency of carbon replacement Desorption schedule, times per week Basis of desorption schedule Hoyt 0.5 Never Dai ly Amount of clothes processed Vic 1.5 After b Detection of perc odor 10 years Vic 2 Never Dai ly Detection of perc odor Hoyt NAa NAa NAa NAa Hoyt >30 NAa NAa ¦ NAa aNA - not available. b0nce a month, should be once every 2 weeks. 51 ------- TABLE 4-2 DALLAS COUNTY SURVEY: COMMERCIAL DRYCLEANERS WITH 1 to 4 EMPLOYEES Number of employees Clothes processed per month Perc consumed per month kg lb kg lb 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 16 22 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 al1 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 52 ------- TABLE 4.3 HAMILTON COUNTY SURVEY: COMMERCIAL DRYCLEANERS WITH 1 to 4 EMPLOYEES Number of employees Clothes processed per month Perc consumed per month kg lb kg lb 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 (conti nued) 53 ------- TABLE 4.3 (continued) Number of employees Clothes processed per month Perc consumed per month kg lb kg lb 4 1964 4330 319 '703 4 2357 5196 159 351 4 2357 5196 319 703 4 2946 6495 121 267 4 1375 3031 928 2046 4 3534 7794 1276 2813 4 1768 3897 319 703 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 54 ------- TABLE 4-4 DALLAS COUNTY SURVEY: COMMERCIAL DRYCLEANERS WITH 5 to 9 EMPLOYEES Number of employees Clothes processed per month Perc consumed per month kg lb kq ID 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: Average emission rate: 14.0 kg perc/100 kg clothes 55 ------- TABLE 4-5 HAMILTON COUNTY SURVEY: COMMERCIAL DRYCLEANERS WITH 5 to 9 EMPLOYEES Number of employees Clothes processed per month Perc consumed per month kg lb kg lb 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 emission rate: 19.4 kg perc/100 kg clothes Average emission rate for both counties: 15.8 kg perc/100 kg clothes 56 ------- TABLE 4-6 DALLAS COUNTY SURVEY: COMMERCIAL DRYCLEANERS WITH 10 to 19 EMPLOYEES Number of employees Clothes processed per month Perc consumed per month kg lb kg lb 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 57 ------- TABLE 4-7 HAMILTON COUNTY SURVEY: COMMERCIAL DRYCLEANERS WITH 10 to 19 EMPLOYEES Number of employees Clothes processed per month Perc consumed per month kg lb kg lb 10 1178 2598 408 900 10 11784 25980 1062 2341 10 3388 7469 306 675 10 3535 7794 1276 2813 12 2945 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 58 ------- TABLE 4-8 DALLAS COUNTY SURVEY: COMMERCIAL DRYCLEANERS WITH g 20 EMPLOYEES Number of employees Clothes processed per month Perc consumed per month kg lb kg lb 33 16511 36400 689 1519 40 3931 8666 765 1687 Total 20442 45066 1454 3206 Average 10221 22533 727 1603 Number of drycleaners surveyed: 2 Average emission rate: 11.8 kg perc/100 kg clothes 59 ------- TABLE 4-9 HAMILTON COUNTY SURVEY COMMERCIAL DRYCLEANING WITH £ 20 EMPLOYEES Number of employees Clothes processed per month Perc consumed per month kg lb kg lb 24 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 60 ------- perc consumed per 100 kg of clothes cleaned) was calculated for each employee classification. These figures were used in Section 2 to calculate industry emissions from the commercial drycleaning sector. The data were plotted for each employment size category in Figures 4-2 through 4-5. It is apparent that there is a wide scatter of the data. A least square regression analysis was performed for each classification. Correlation factors ranged from 9 to 50 percent. Because of the poor correlation obtained for a linear fit, an arithmetic average of the emission factor and the clothes processed were reported. An arithmetic average equally weights each data point obtained in the survey. 4.4 RECOMMENDATIONS In performing a demographic study of an industry, PEDCo recommends using the most recent issue of the CBP publication. To obtain a list of local establishments in a particular industry, the yellow pages is the best source of information. A list from one of the organizations which complies business lists provides the same information as the yellow pages but at an additional cost. The primary advantage of using a business list is that it eliminates the risk of duplication in surveying. Two other techniques, canvassing local areas and mass mail- ings, could also be used. However, canvassing areas is a brute- force method which requires adequate personnel resources, and mass mailings may result in a lack of response from a significant number of establishments. Telephone contact, with follow-up letters when necessary, is the recommended method. 61 ------- 7,000 6,000 5,000 k, 000 3,000 2,000 1 ,000 i i r O CP o o o o q2oo o o o o oO OO o o o o o o o 2o o2 O o o o ° o 0-2 J L 100 300 500 700 900 1,100 PERC CONSUMED (kg/month) Figure 4-2. Clothes processed versus perc consumed bv commercial drycleaners in Dallas and Hamilton Counties (1 to 4 employees). 62 ------- 11,781* 7,000 6,000 5,000 ^ f 000 3,000 2,000 — 1 ,000 (1,531) 100 300 500 700 900 1,100 PERC CONSUMED (kg/month) Figure 4-3. Clothes processed versus Derc consumed by commercial dryclaaners in Dallas and Hamilton Counties (5 to 9 employees). 63 ------- 12,383 11,78^ 7,000 6,000 5,000 - Moo 3,000 2,000 — 1 ,000 — 100 300 500 700 900 PERC CONSUMED (kg/month) 1 ,100 Figure 4-4. Clothes processed versus perc consumed by commercial drycleaning in Dallas and Hamilton Counties (10 to 19 employees). 64 ------- 17,500 15,000 — 12,500 — 10,000 7,500 5,000 — 2,530 100 Figure 4-5. 300 500 700 900 PERC CONSUMED (kg/month) 1 ,100 Clothes processed versus oerc consumed by commercial drycleaners in Dallas and Hamilton Counties ( 20 employees). 65 ------- REFERENCES 1. 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. 2. Gill, W. , National Automatic Laundry and Cleaning Council, Chicago, Illinois, Telephone Conversation, W. Mason, Septem- ber, 1979. 3. Perchloroethylene Dry Cleaning. Background Information for Proposed Standards, Office of Air Quality Planning and Standards. Research Triangle Park, NC. EPA 450/3-79-029a, August 1979. 4. Control of Volatile Organic Emissions from Perchloroethylene Dry Cleaning Systems, Guideline Series, U.S. EPA, Office of Air Quality Planning and Standards. Research Triangle Park, NC. EPA 450/2-78-050, December 1978. 5. King, C., Kleen-Rite Inc., St. Louis, MO, Telephone Conver- sion, M. Anastas, September 17, 1979. 6. Personal communication to M. Anastas by an Equipment Manufac- turer, August 7, 1979. 7. Sluizer, M., Telephone Conversation with M. Anastas, Septem- ber 28, 1979. 8. Stoddard, J., Telephone Conversation, M. Anastas, Multimatic Corp., Palisades Park, NJ, October 4, 1979. 9. County Business Patterns, 1976, U.S. Department of Commerce, Bureau of the Census, Washington, D.C. 10. Worldwide Geographical Location Codes, General Services Administration, Office of Finance, Washington, D.C., February 1972. 11. Gill, announcement made at the NAPCTAC meeting, August 1979. 12. National Ambient Air Quality Standards - States Attainment Status, In-house compilation, PEDCo Environmental, Inc., 1979 . 13. Federal Air Quality Control Regions, U.S. EPA, Office of Air Programs, Rockville, MD, January 1972. 14. Moss, S., Miracle Core Chemical Industries, Inc., Telephone Communication to W. Mason, August 24, 1979. 66 ------- 15. 16, 17 18 19 20 21 22 23 24 25 26 What Every Drycleaner Should Know About Perchloroethylene, Dow Chemical Company, Form No. 100-5437-77, 1977. Watt, IV, and W. F. Fisher, "Results of Membership Survey of Dry Celaning Operations," IFI Special Reporter No. 3-1, January-February 1975. EPA 450/3-79-029a. Kleeburg, C. F., Letter of J. F. Durham, Dry Cleaning Plant Test at Texas Industrial Services, San Antonio, Texas, May 14, 1976. Siu, R., "Cintas Welcomes OSHA-EPA is Impressed", Textile Rental, July 1979. Air Pollution Emission Test - Westwood Cleaners, Kalawazoo, MI, U.S. EPA Office of Air and Waste Management, Office of Air Quality Planning and Standards, Emission Measurement Branch. Research Triangle Park, NC. Report No. 76-DRY-3 EPA Contract 68-02-1403, Task No. 23, June 25, 1976. Air Pollution Emission Test - Hershey Drycleaners and Laundry, Hershey, PA, Report No. 76-Dry-l, Contract No. 68-02-1400, Task No. 21. Air Pollution Emission Test - Texas Industrial Services, San Antonio, TX. Contract No. 68-02-1403, Task No. 21, June 25, 1976. "Measurement of Volatile Organic Compounds", Guideline Services No. 450/2-78041. Mantell, C. L., Carbon and Graphite Handbook, Interscience Publishers, NY, 1968. Richards, D. W., and K. S. Surprenant. Study to Support New Source Performance Standards for Solvent Metal Cleaning Operations. Prepared for Emission Standards and Engineering Division, Office of Air Quality Planning, U.S. EPA, Contract No. 68-02-1329, Task No. 9, June 1976. Causes of Excessive Loss of Perchloroethylene, International Fabricare Institute, Silver Spring, MD, Bulletin No. p. 91, 1969. "Standard Method of Test for Dilution of Gasoline Engine Crankcase Oils", American National Standards Institute. 67 ------- APPENDIX COIN-OPERATED, COMMERCIAL, AND INDUSTRIAL DRYCLEANING ESTABLISHMENT INVENTORY AND PERC EMISSIONS INVENTORY ------- TABLE A-l. COIN-OPERATED LAUNDRIES AND DRYCLEANERS BY EPA REGION - 1976 (Ref. 9 - SIC 7215) EPA Regions Number of estab- 1 i sh- 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 I Connecti cut 125 113 11 1 - - - - Mai ne 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 - 1 - Subtotal 1183 1062 79 30 11 - 1 - Region III Del aware 24 14 5 4 1 - - - District of Columbia 30 24 5 1 - - - - Maryland 217 177 31 3 3 3 - - Pennsylvani a 442 361 63 11 6 1 - - Vi rgi ni a 280 241 33 5 1 - - - West Virginia 109 97 11 - 1 - - - Subtotal 1102 914 148 24 12 4 — — ------- TABLE A-l (continued) Number Number of establishments by employment-size class of estab- 10 20 50 100 250 1 i s h - 1 to 4 5 to 9 to to to to to EPA Regions ments 19 49 99 249 499 Region IV A1abama 206 183 16 6 1 - - - Florida 666 593 57 14 2 - - - Georgi a 229 199 25 2 3 - - - Kentucky 265 233 29 1 - 1 1 - Mi ssi ssi ppi 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 11 linois 794 622 149 15 7 1 - Indiana 489 382 90 16 1 - - - Michigan 592 425 140 24 3 " - - Mi nnesota 148 121 19 6 2 - - - Ohio 674 540 110 17 7 - - - Wi sconsi n 225 187 30 5 2 1 - - Subtotal 2922 2277 538 83 22 2 - — Region VI Arkansas 146 139 7 . - - - - - Loui si ana 132 115 13 2 2 - - - New Mexico 96 72 17 7 - - - - Oklahoma 201 184 12 5 - - - - Texas 934 864 56 9 3 1 1 - Subtotal 1509 1374 105 23 5 1 1 ------- TABLE A-l (continued) EPA Regions Number of estab- 1 i sh- 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 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 - - 1 - - South Dakota 40 39 1 - - - - - Utah 68 55 12 1 - - - - Wyomi ng 30 27 2 1 • - - - - Subtotal 361 314 39 5 2 1 - _ Region IX Ari zona 119 103 12 2 2 - - - Cali forni a 614 484 91 28 9 - 1 1 Hawai i 38 34 4 - - - - - Nevada 45 36 8 1 - - - - - Subtotal 816 657 115 31 11 - 1 1 Region X A1aska 29 17 7 2 3 - - - Idaho 53 44 8 1 - - - - Oregon 109 87 16 5 - 1 - - Washi ngton 172 137 28 6 1 - - - Subtotal 363 285 59 14 4 1 - - Total United States 11804 10022 1408 276 81 10 6 1 ------- TABLE A-2. COMMERCIAL DRYCLEANING PLANTS EXCEPT RUG BY EPA REGION - 1976 (Ref. 9 - SIC 7216) EPA Regions Number of estab- 1 i sh- 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 I Connecti cut 346 208 81 45 12 - - - Mai ne 50 36 4 7 3 - - - Massachusetts 543 309 143 69 18 3 1 - 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 1 - 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 Del aware 53 30 11 9 3 - - - District of Columbia 103 50 27 18 8 - - - Maryland 351 145 110 68 28 - - - Pennsylvani a 928 510 250 113 48 7 - - Vi rgi ni a 554 277 172 74 26 5 - - West Virginia 126 64 39 16 7 - - - Subtotal 2115 1076 609 298 120 12 - - ------- TABLE A-2 (continued) EPA Regions Number of estab- 1 i sh- 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 A1abama 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 - - Missi ssippi 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 - Indi ana 440 268 101 51 16 2 2 - Michigan 754 411 212 102 26 2 1 - Mi nnesota 254 139 69 29 15 2 - - Ohi o 977 555 246 118 51 6 1 - Wi sconsi n 336 213 84 27 8 3 1 - Subtotal 3680 2067 959 468 157 20 9 — Region VI Arkansas 215 122 56 32 3 2 - - Loui si ana 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 _ ------- TABLE A-2 (continued) EPA Regions Number of estab- 1 i sh- 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 VII Iowa 206 134 42 20 9 1 - - Kansas 229 156 54 15 4 - - - Mi ssouri 432 258 114 45 14 1 - - Nebraska 133 82 32 11 7 - 1 - Subtotal 1000 630 242 91 34 2 1 ' 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 - - Wyomi ng 37 22 11 4 - - - - Subtotal 579 344 161 47 24 3 Region IX Arizona 134 80 25 17 10 2 - - Cali forni a 1826 1081 481 200 54 8 2 - Hawai i 37 15 10 5 5 1 1 - Nevada 52 17 12 17 6 - - - Subtotal 2049 1193 528 239 75 11 3 Region X Alaska 17 9 2 2 1 2 1 - Idaho 61 36 20 4 1 - - - Oregon 175 126 33 12 4 - - - Washi ngton 309 202 75 26 5 1 - - Subtotal 562 373 130 44 11 3 1 Total United States 19953 11676 5106 2284- 755 106 26 - ------- TABLE A-3. INDUSTRIAL LAUNDERERS BY EPA REGION - 1976 (Ref. 9 - SIC 7218) Number Number of establishments by employment- size class of estab- 10 20 50 100 250 1 i s h - 1 to 4 5 to 9 to to to to to EPA Regions ments 19 49 99 249 499 Region I Connecti cut 10 1 1 2 2 3 1 - Mai ne 2 - - 1 - 1 - - Massachusetts 23 3 1 3 8 5 2 1 New Hampshire 2 - - - - 2 - - Rhode Island 2 - - - 2 - - - Vermont 1 - - - - 1 - - Subtotal 40 4 2 6 12 12 3 1 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 Del aware 1 - - - - 1 - - District of Columbia - - - - - - - - Maryland 18 4 1 1 3 6 3 - Pennsylvani a 42 8 3 4 10 15 2 - Vi rgi ni a 18 2 2 4 3 4 3 - West Vi rgi ni a 4 1 - - 1 2 - - Subtotal 83 15 6 9 17 28 8 - ------- TABLE A-3 (continued) EPA Regions Number of estab- 1 i sh- 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 16 2 - 3 7 3 1 - Flori da 35 2 4 5 9 9 6 - Georgi a 33 6 4 5 9 7 2 - Kentucky 21 - 3 6 6 5 1 - Missi ssippi 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 111i noi s 45 8 2 5 15 10 5 - Indiana 25 2 5 4 8 3 2 1 Mi chi gan 46 6 6 14 11 3 5 1 Mi nnesota 11 3 3 2 1 - 2 - Oh i o 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 - - Loui si ana 17 1 - 2 7 5 1 1 New Mexico 5 - 1 - 1 3 - - Okl ahoma 14 1 2 2 5 4 - - Texas 62 5 5 5 22 18 6 1 Subtotal 112 9 8 11 43 32 7 2 ------- TABLE A~3 (continued) EPA Regions Number of estab- 1 i sh- ments Number oT establishments by employment-size cTass 1 to 4 5 to 9 10 to 19 20 to 49 50 to 99 100 250 to to 249 499 Region VII Iowa 12 2 3 2 2 2 1 Kansas 15 2 5 2 2 4 - Mi ssouri 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 - - Wyomi ng - - - - - - - Subtotal 14 4 2 1 3 4 - Region IX Ari zona 10 2 - 1 3 3 1 Cali forni a 103 16 3 12 34 24 14 Hawai i - - - - - - - Nevada 5 1 1 - 3 - - Subtotal 118 19 4 13 40 27 15 Region X A1aska _ _ _ _ _ Idaho - - - - - - _ Oregon 10 2 1 5 1 - 1 Washi ngton 11 2 1 - 7 - 1 Subtotal 21 4 2 5 8 - 2 Total United States 906 134 85 126 269 199 87 6 ------- TABLE A-4. TOTAL NUMBER COIN-OPERATED LAUNDRIES AND DRYCLEANERS IN NONTATTAINMENT AREAS BY STATE - 1976 (Ref. 9, 12, 13 - SIC 7215 State Number of estab- 1 i sh- 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 A1abama 69 54 11 4 _ _ - - A1aska - - - - - - - ~ Ari zona 16 14 2 - - - - - Arkansas - - - - - - - - Cali forni a 342 252 59 23 7 - - 1 Colorado 50 37 10 2 1 - - - Connecticut 125 113 11 1 - - - - Del aware 12 4 4 4 - - - - District of Columbia 30 24 5 1 - - - - Florida 387 340 39 6 2 - - - Georgi a 58 51 7 - - - - - Hawai i - - - - - - - - Idaho - - - . - - - - - 111i noi s 521 398 106 10 7 - - - Indi ana 198 140 48 9 1 - - - Iowa 10 8 1 1 - - - - Kansas 32 28 1 3 - - - - Kentucky 39 29 9 - - - 1 - Loui si ana 22 20 - - 2 - - - Mai ne 18 14 4 - - - - - Maryland 86 66 15 1 2 2 - - Massachusetts 230 192 29 6 3 - - - Mi chi gan 390 272 95 20 3 - - - Mi nnesota 27 13 8 4 2 - - - Mi ssissippi - - - - - - - - ------- TABLE A-4 (continued) State Number of estab- 1 i sh- 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 Mi ssouri 97 78 11 8 - - - - Montana - - - - - - - - Nebraska - - - - - - - - Nevada 37 30 6 1 - - - - New Hampshire - - - - - — — _ New Jersey 281 243 28 5 5 - - - New Mexico 29 23 4 2 - - - - New York 902 819 51 25 6 - 1 - North Carolina 21 18 1 2 - - - - North Dakota - - - — - — ~ Ohio 303 224 60 14 5 - - - 0 k1ahoma 84 71 9 4 - - - - Oregon 29 19 7 2 - 1 - - Pennsylvani a 442 361 63 11 6 1 - - Rhode Island 57 48 8 . - 1 - _ _ South Carolina 24 19 5 - - - - - South Dakota - - - - - - - - Tennessee 77 65 9 3 - " - - Texas 500 454 35 6 3 1 1 - Utah 30 24 6 - - - _ — Vermont - - - - - - - - Vi rgi ni a 27 18 7 1 1 " - - Washi ngton 70 53 10 6 1 " - - West Virginia 13 10 2 - 1 - - - Wi sconsi n 39 30 6 3 - - — — Wyomi ng - - - - - - - - United States 5724 4676 792 188 59 5 3 1 ------- TABLE A-5. COMMERCIAL DRYCLEANING PLANTS EXCEPT RUG IN NONATTAINMENT AREAS BY STATE - 1976 (Ref. 9, 12, 13, - SIC 7216) State Number of estab- 1 i s h- 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 Alabama 148 76 37 26 9 - - - A1aska - - - - - - - - Ari zona 30 19 5 3 3 - - - Arkansas 40 10 14 11 3 2 - - Cali forni a 1383 779 376 169 49 8 2 — Colorado 220 123 71 16 9 1 - - Connecti cut 346 208 81 45 12 - - - Del aware 39 20 9 9 1 - - - District of Columbia 103 50 27 18 8 - - - Florida 434 220 135 53 23 2 1 — Georgia 346 179 103 48 12 4 - - Hawai i - - - - - - - - Idaho - - - . - - - - - 111i noi s 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 - - Loui si ana 201 108 58 28 5 2 - - Mai ne 15 8 2 3 2 - - - Maryland 217 78 73 46 20 - - - Massachusetts 543 309 143 69 18 3 1 - Michigan 614 320 181 88 22 2 1 - Mi nnesota 154 65 54 22 11 2 - - Mississippi - - - - - — ------- TABLE A-5 (continued) State Number of estab- 1 i sh- inents 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 Mi ssouri 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 - - - - - - - - Oh i o 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 - - South Carolina 83 16 34 24 7 2 - - South Dakota - - - - - - - - Tennessee 206 87 59 42 17 1 - - Texas 757 392 176 121 53 13 2 - Utah 68 31 24 7 5 1 - - Vermont . 14 5 3 5 1 - - - Vi rgi ni a 309 149 95 46 14 5 - - Washi ngton 188 123 46 16 3 - - - West Virginia 18 3 10 1 4 - - - Wi sconsi n 178 110 43 15 7 2 1 - Wyomi ng - - - - - - - - United States 13149 7372 3446 1647 576 85 23 - ------- TABLE A-6. INDUSTRIAL LAUNDERERS IN NONATTAINMENT AREAS BY STATE - 1976 (Ref. 9, 12, 13 - SIC 7218) State Number of estab- 1 i s h - 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 A1abama 8 - - 2 4 2 - - Alaska - - - - - - - - Ari zona 1 - - - - - 1 - Arkansas 4 - - - 2 2 - - Cali forni a 77 13 3 9 18 22 12 - Colorado 4 1 - - 2 1 - - Connecticut 10 1 1 2 2 3 1 - Del aware 1 - - - - 1 - - District of Columbia - - - - - - - - Florida 29 1 3 4 7 9 5 - Georgia 12 2 3 - 1 4 2 - Hawai i - - - - - - - - Idaho - - - . - - - - - Illinois 32 6 1 2 8 10 5 - Indi ana 8 - 1 1 3 2 - 1 Iowa - - - - - - - - Kansas 5 - 1 - 1 3 - - Kentucky 11 - - 3 4 3 1 - Louisiana 8 1 - 1 1 3 1 1 Mai ne 1 - - - - 1 - - Maryland 5 - - - 2 2 1 ' - Massachusetts 23 3 1 3 8 5 2 1 Mi chi gan 32 4 3 8 9 2 5 1 Mi nnesota 5 2 - - 1 - 2 - Missi ssippi - - - - - - " 1 - ------- TABLE A-6 (continued) State Number of estab- 1 i s h- 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 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 7 10 - Oklahoma 10 - 1 1 4 4 - Oregon 5 1 - 2 1 — 1 Pennsylvani a 42 8 3 4 10 15 2 Rhode Island 2 2 South Carolina 2 - - 1 - 1 - - South Dakota - - - - - - ~ — Tennessee 18 2 1 1 5 6 3 — Texas 36 2 2 3 12 11 5 1 Utah 2 1 — — 1 Vermont - - - - - - - - Vi rgi ni a 7 - — 2 4 1 Washi ngton 1 - - - - - 1 - West Vi rginia - - - - - — ~ " Wi scons in 4 " 1 2 1 Wyomi ng - - - - - - - - United States 559 74 41 65 154 151 69 5 ------- TABLE A-7. COIN-OPERATED LAUNDRIES AND DRYCLEANERS (SIC 7215) IN ATTAINMENT AREAS BY STATE - 1976 State Number of estab- 1 i sh- ments Number of establi shments 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 A1abama 137 129 5 2 1 _ _ _ A1aska 29 17 7 2 3 - - - Ari zona 103 89 10 2 2 - - - Arkansas 146 139 7 - - - - - Cali forni a 272 232 32 5 2 - 1 - Colorado 102 94 7 1 _ _ Connecti cut - - - - - - - - Del aware 12 10 1 - 1 - - - District of Columbia - - - - - - - - F1ori da 279 253 18 8 - - - - Georgi a 171 148 18 2 3 - - - Hawai i 38 34 4 - - - - - Idaho 53 44 8 1 - - - - 111i noi s 273 224 43 5 - 1 - - Indi ana 291 242 42 7 - - - - Iowa 153 134 14 5 - - - - Kansas 137 115 20 2 - - - - Kentucky 226 204 20 1 - 1 - - Loui siana 110 95 13 2 - - - - Mai ne 55 52 3 - - - - - Mary1 and 131 111 16 2 1 1 - - Massachusetts - - - - - - - - Mi chi gan 202 153 45 4 - - - - Mi nnesota 121 108 11 2 - - - - Mi ssi ssippi 148 141 6 1 - - - - ------- TABLE A-7 (continued) State Number of estab- 1 i sh- 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 Mi ssouri 199 176 20 2 1 - - - Montana 46 39 6 - 1 - - — 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 — — 1 Ohio 371 316 50 3 2 - - - Oklahoma 117 113 3 1 - - - — Oregon 80 68 9 3 - - — — Pennsylvani a - - - — " Rhode Island — — — — " South Carolina 144 131 8 4 1 - - - South Dakota 40 39 1 - - - - "" Tennessee 203 190 10 2 1 - - Texas 434 410 21 3 - - - ~~ Utah 38 31 6 1 — """ " Vermont 32 30 2 - - - - - Vi rgi ni a 253 223 26 4 - - - — Washi ngton 102 84 18 - - - — — West Vi rginia 96 87 9 - - - - Wi sconsi n 186 157 24 2 2 1 " Wyomi ng 30 27 2 1 - - - - United States 6080 5346 616 88 22 5 3 ------- TABLE A-8. COMMERCIAL DRYCLEANERS (SIC 7216) IN ATTAINMENT AREAS BY STATE - 1976 State Number of estab- 1 i sh- 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 A1abama 252 162 61 21 5 2 1 - A1aska 17 9 2 2 1 2 1 - Ari zona 104 61 20 14 7 2 - - Arkansas 175 112 42 21 - - - - Cali form" a 443 302 105 31 5 — — — Colorado 74 49 15 6 4 " - - Connecti cut - - - - - - - - Del aware 14 10 2 - 2 - - - District of Columbia - - - - - - - - F1ori da 227 127 66 29 5 _ Georgi a 280 148 80 41 11 - - - Hawai i 37 15 10 5 5 1 1 - Idaho 61 36 20 - 4 1 - - - 111i noi s 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 - - Loui siana 164 103 45 12 4 - - - Mai ne 35 28 2 4 1 — — — Maryland 134 67 37 22 8 - - - Massachusetts - - - - - - - - Mi chi gan 140 91 31 14 4 - - - Mi nnesota 100 74 15 7 4 - - - Missi ssippi 275 158 87 22 8 — — ~ ------- TABLE A-8 (continued) Number Number of establishments by employment-size class of estab- 10 20 50 100 250 1 i s h - 1 to 4 5 to 9 to to to to to State ments 19 49 99 249 499 Mi ssouri 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 1 - - New York - - - - - - - - North Carolina 612 316 191 78 22 5 - - North Dakota 50 34 11 2 2 1 - - Ohio 208 134 52 17 3 2 - - Oklahoma 155 124 21 9 1 - - - Oregon 78 67 8 2 1 - - - Pennsylvani a - - - - - - - - Rhode Island - - - - - - - South Carolina 250 137 67 37 8 1 - - South Dakota 44 28 9 6 1 - - - Tennessee 191 119 52 17 3 - - - Texas 603 429 111 ¦48 15 - - - Utah 19 15 3 - 1 - - - Vermont 19 11 4 3 1 - - - Vi rgini a 245 128 77 28 12 - - - Washi ngton 121 79 29 10 2 1 - - West Vi rgi ni a 108 61 29 15 3 - - - Wi sconsi n 158 103 41 12 1 1 - - Wyomi ng 37 22 11 4 - - - - United States 6804 4304 1660 637 79 21 3 - ------- TABLE A-9. INDUSTRIAL LAUNDERERS (SIC 7218) IN ATTAINMENT AREAS BY STATE - 1976 State Number of estab- 1 i sh- ments Number of establi shments 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 A1abama 8 2 1 3 1 1 - A1aska - - - - - - - - Ari zona 9 2 - 1 3 3 - - Arkansas 10 2 - 2 6 - - - Cal i form" a 26 3 - 3 16 2 2 - Colorado 7 2 1 1 - 3 - - Connecticut - - - - - - - - Del aware - - - - - - - - District of Columbia - - - - - - - - F1ori da 6 1 1 1 2 - 1 - Georgia 21 4 1 5 8 3 - - Hawai i - - - - - - - - Idaho - - - - - - - - 111i noi s 13 2 1 O o 7 - - - Indiana 17 2 4 3 5 1 2 - Iowa 12 2 3 2 2 2 1 - Kansas 10 2 4 2 1 1 - - Kentucky 10 - 3 3 2 2 - - Loui siana 9 - - 1 6 2 - - Mai ne 1 - - 1 - - - - Maryland 13 4 1 1 1 4 2 - Massachusetts - - - - - - - - Mi chi gan 14 2 3 6 2 1 - - Mi nnesota 6 1 3 2 - - - - Mi ssi ss ippi 10 3 1 2 2 1 1 - ------- TABLE A-9 (continued) State Number of estab- 1 i sh- 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 Mi ssouri 12 2 - 1 6 2 1 - Montana - - - - - - - Nebraska 6 3 - 1 1 1 - - Nevada 2 1 1 - - - - - New Hampshire - - - - - - - - New Jersey - - - - - - - - New Mexico 4 - 1 - 1 2 - - New York - - - - - - - - North Carolina 23 1 - 4 11 4 2 1 North Dakota - - - - - - - - Oh i o 10 2 4 2 1 1 - - Oklahoma 4 1 1 1 1 - - - Oregon 5 1 1 3 - - - - Pennsylvania - - - - - - - - Rhode Island - - - • - - - - - South Carolina 9 2 - 1 4 1 1 - South Dakota - - - - - - - - Tennessee 10 2 1 2 4 - 1 - Texas 26 3 3 2 10 7 1 - Utah 1 - 1 - - - - - Vermont 1 - - - - 1 - - Vi rgi ni a 11 2 2 4 1 - 2 - Washi ngton 10 2 1 - 7 - - - ------- TABLE A-10. 1976 PERC EMISSIONS BY EPA REGION, METRIC TONS EPA Region Co in~op Commercial industrial Region I Connecticut Mai ne Massachusetts New Hampshire Rhode Island Vermont Subtotal 174.2 101.7 320.6 57.1 79.4 44.6 777.6 1729.1 250.6 2743.5 233.0 371.6 180.9 5508.7 149.8 30.0 344.6 30.0 30.0 15.0 599.4 Region II New Jersey New York Subtotal 391.6 1257.1 1648.7 4111.2 9706.5 13817.7 419.5 943.8 1363.3 Region III Delaware District of Columbia Mary 1 and Pennsylvania Vi rgi ni a West Virginia Subtotal 33.4 41.8 302.4 616.0 390.2 151.9 1535.7 276.8 558.0 1946.1 4780.0 2887.7 653.7 11102.3 15.0 269.7 59.9 269.7 59.9 1243.5 Region IV A1abama Florida Georgia Kentucky Mi ssissippi North Carolina South Carolina Tennessee Subtotal 287.1 928.2 319.2 369.3 206.3 461.3 234.1 390.2 3195.7 2005.7 3386.3 3221.5 1483.4 1345.6 3470.7 1781.9 2068.3 18763.4 239.7 524.3 494.4 314.6 149.8 419.5 164.8 419.5 2726.6 Region V 111inoi s Indiana Mi chi gan Mi nnesota Ohio Wi sconsi n Subtotal 1106.6 681.5 825.1 206.3 939.4 313.6 4072.5 4799.3 2204.5 3834.4 1314.1 5011.7 1633.8 18797.8 674.2 374.5 689.1 164.8 809.0 164.8 2876.4 A-2 3 ------- TABLE A-10 (continued) EPA Region Coin-ou Commercial Industrial Region VI Arkansas 203.5 1079.0 209.7 Loui si ana 184.0 1809.2 254.7 New Mexico 133.8 444.3 74.9 Qklahoma 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 Mi ssouri 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 Wyomi ng 41.8 177.4 -- Subtotal 503.0 2870.7 209. 7 Region IX Ari zona 165.9 704.2 149.8 Cali forni a 855.7 9066.6 1543.1 Hawai i 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 Washi ngton 239.7 1474.7 164.8 Subtotal 505.9 2688.6 314.6 Total 16450.9 100315.1 13573.2 A-24 ------- TABLE A-11. 1976 PERC EMISSION IN NONATTAINMENT AREAS, METRIC TONS State Coi n-op Commerci al Industrial Alabama 96.2 785.9 119.9 Alaska -- -- -- Ari zona 22.3 156.3 15.0 Arkansas -- 244.1 59.9 Cali forni a 476.6 6995.9 1153.6 Colorado 69.7 1093.7 59.9 Connecti cut 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 80.8 1785.0 179.8 Hawai i -- -- -- Idaho -- -- -- 111i noi s 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 Mai ne 25.1 85. 3 15.0 Maryland 119.9 1236.5 74.9 Massachusetts 320.6 2743.5 344.6 Michigan 543.6 3155.0 479.4 Minnesota 37.6 839.2 74.9 Mississippi - - Mi ssouri 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.b 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-25 ------- TABLE A-ll (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 -- Vi rgi nia 37.6 1634.5 104.9 Washi ngton 97.6 894.4 15.0 West Virginia 18.1 111.4 -- Wisconsin 54.4 887.3 59.9 Wyomi ng -- -- -- United States 7977.7 67219.4 8375.0 A-26 ------- TABLE A-12. 1976 PERC EMISSION IN ATTAINMENT AREAS, METRIC TONS State Coi n-op Commerci al Industri al Alabama 190.9 1219.8 119.8 Alaska 40.4 102.0 -- Ari zona 143.6 547.9 134.8 Arkansas 203.5 834.9 149.8 Cali fornia 379.1 2070.7 389.5 Colorado 142.1 364.2 104.9 Connecticut -- -- -- Del aware 16.7 71.6 -- District of Columbia -- -- -- Florida 388.8 1129.7 89.8 Georgi a 238.4 1436.5 314.6 Hawai i 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 Loui siana 153. 3 787.1 134.8 Maine 76.6 165.3 15.0 Maryland 182.5 709.6 194.8 Massachusetts -- -- -- Michigan 281.5 679.4 209.7 Mi nnesota 168.7 474.9 89.9 Mi ssi ssi ppi 206.3 1345.6 149.8 Mi ssouri 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 -- -- A-27 ------- TABLE A-12 (continued) State Coi n-op Commerci al Industri al 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 Wi sconsi n 259.2 746.5 104.9 Wyoming 41.8 177.4 -- United States 8473.2 33095.7 5198.2 A-28 ------- |