Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711

BACKGROUND:

• Dry cleaners are a major source of perchloroethylene (PCE or "perc"), one of the toxic air pollutants Congress has required the EPA to regulate under the Clean Air Act Amendments of 1990. Perchloroethylene is suspected of causing cancer.

• Under Section 112 of the Clean Air Act, the EPA proposed national emission standards for hazardous air pollutants (NESHAP) to limit PCE emissions from both new and existing dry cleaning facilities on December 9, 1991, the first of several rules the EPA will be issuing to control emissions of air toxics.

• In response to public comments received on the proposed NESHAP, the EPA published a notice of availability of new information on control of PCE emissions during clothing transfer at dry cleaning facilities using transfer dry cleaning machines on October 1, 1992. Additional comments were received.

REQUIREMENTS OF EPA DRY CLEANERS RULE:

• The rule breaks dry cleaners into three separate categories -- small "area" sources, large "area" sources, and "major" sources -- and contains different requirements for each category. (See Table 1.)

• There are two types of dry cleaning machines: dry-to-dry and transfer. A dry-to-dry machine consists of one machine, which does both the washing and the drying of the articles being cleaned. A transfer machine consists of two machines: a washer and a dryer. Clothing is transferred from the washer to the dryer at transfer machines, and this step is a significant source of PCE emissions.

• The EPA's final rule requires all new dry cleaning machines to be dry-to-dry machines. It does not, however, require the replacement of existing transfer machines with new dry-to-dry machines.

• There are two sources of PCE emissions at dry cleaning facilities: process vent emissions (i.e., the dry cleaning machine vent); and fugitive emissions (e.g., clothing transfer at transfer machines, equipment leaks, open containers, etc.). Process vent emissions are controlled through the use of refrigerated condensers or carbon adsorbers. Fugitive emissions from clothing transfer at transfer machines are controlled through room enclosures. Other fugitive emissions are controlled through leak detection/repair, and pollution prevention activities (e.g., good housekeeping).

• The EPA's rule requires control of process vent emissions at all new dry cleaning facilities. It also requires control of process vent emissions at large area source and major source existing dry cleaning facilities.

• The rule requires control of fugitive emissions at all new dry cleaning facilities. It also requires control of fugitive emissions at all existing dry cleaning facilities with the exception of fugitive emissions from clothing transfer at transfer machines. Only transfer machines at major source existing dry cleaning facilities are required to control fugitive emissions from clothing transfer.

• The rule requires the use of refrigerated condensers to control process vent emissions at new dry cleaning facilities. It also requires the use of refrigerated condensers to control process vent emissions at existing dry cleaning facilities, except those existing facilities that have already installed a carbon adsorber for control of process vent emissions. Existing dry cleaning facilities that currently use a carbon adsorber may continue to use this carbon adsorber to comply with the requirements of the rule.

• All new dry cleaning facilities must comply with the new EPA rule when they begin operation. Existing dry cleaning facilities have 36 months to comply.

IMPACTS:

• Nationwide Impacts

In 1996 about 25,000 commercial and industrial dry cleaning facilities will be in operation. Although the dry cleaning industry exhibits little growth, about 7,700 of these 25,000 facilities will be new facilities built to replace existing facilities that retire. Of these 7,700 new facilities, about 400 would likely be uncontrolled in the absence of the rule and, as a result of the rule, will be required to install process vent control. In addition, the EPA rule will require about 3,200 existing uncontrolled facilities to install controls on process vents.

The rule will result in a total maximum national emissions reduction of perchloroethylene of 6,600 megagrams (Mg) (7,300 tons) from process vent control and 25,800 Mg (28,400 tons) from leak detection and repair (LDAR) from projected 1996 emission levels.

Energy: Total maximum national increase in electricity use (needed to operate the control devices) of 0.28 gigawatt hours per year (GWh/yr) in 1996 for new facilities and 2.5 Gwh/yr for existing facilities.

Annualized Cost: Total national increase of $3.9 million/year for process vent control in 1996, if solvent savings are included. Total national increase of $9.0 million in 1996, if solvent savings are not included. Total national cost savings of $7.6 million for LDAR, if cost savings are included. Total national increase or $10.0, if solvent savings are not included.

Capital Cost: Total national increase of $3 million for new dry cleaning facilities and $32 million for existing dry cleaning facilities in 1996.

• Typical facility impacts for an existing, uncontrolled, 35- pound dry-to-dry machine located at an area source dry cleaning facility that would have to install a refrigerated condenser would be as follows:

Perchloroethylene Emission Reductions: Individual reduction of 0.8 Mg/yr (0.9 tons per year) from process vent control and 0.8 Mg/yr (0.9 tons per year) from LDAR from projected 1996 emission levels.

Wastewater: Total maximum increase of 0.03 kilograms/yr (0.07 pounds per year) of PCE in wastewater in 1996.

Solid Waste: No increase for the typical facility.

Noise: No incremental impacts.

Energy: The increase in electricity use (needed to operate refrigerated condenser) of 604 kilowatt hours per year in 1996.

Annualized Cost: Increase of $1,100/year for process vent control and $460/year for LDAR, monitoring, reporting, and record keeping.

Capital Cost: Increase of $6,300/year in 1996.

Table 1. Requirements of the PCE Dry Cleaning Rule for Three Kinds of Affected Sources