1
k:\
0154­
02­
010\
DCTM_
ARP.
wpd
MEMORANDUM
TO:
Rhea
Jones,
U.
S.
Environmental
Protection
Agency,
OAQPS
(
C539­
03)

FROM:
Eric
Goehl
and
Mike
Heaney,
Eastern
Research
Group
(
ERG),
Morrisville
DATE:
August
25,
2004
SUBJECT:
Industry
Trends
of
Major
and
Area
Source
Dry
Cleaners
1.0
INTRODUCTION
The
dry
cleaning
industry
is
made
up
of
both
major
and
area
sources.
Major
sources
are
defined
in
the
NESHAP
as
those
facilities
that
have
dry­
to­
dry
machines
and
use
more
than
2100
gallons
of
PCE
annually
or
facilities
that
have
dry­
to­
dry
machines
and
transfer
machines
and
use
more
than
1800
gallons
of
PCE
annually.
Major
sources
are
a
small
fraction
of
the
total
population
of
the
industry.
The
15
major
sources
use
approximately
2%
of
the
total
perchloroethylene
(
PCE)
used
in
the
dry
cleaning
industry.
Area
sources
are
facilities
that
use
less
than
the
major
source
thresholds.
In
the
NESHAP,
area
sources
are
divided
into
large
and
small
areas
sources
based
on
PCE
consumption.
According
to
data
from
the
U.
S.
Census
there
are
approximately
32,000
dry
cleaners.
Approximately
27,000
of
these
dry
cleaners
use
PCE
as
their
main
dry
cleaning
solvent.
Except
for
the
15
major
source
PCE
dry
cleaners,
the
remainder
of
these
facilities
are
area
sources.
In
2002,
all
dry
cleaners
used
3.5
million
gallons
of
PCE
(
TCATA,
July
2003).

Major
and
area
sources
can
have
industrial,
commercial,
or
speciality
type
operations
(
i.
e.,

leather
garment
cleaners).
The
industrial
dry
cleaners
typically
clean
garments
for
large
industries
like
the
automotive
producers.
These
garments
include
work
gloves,
aprons,
and
uniforms.
The
work
gloves
and
aprons
are
often
made
of
leather
or
other
thick
materials.
Because
of
the
heavy
garment
materials
and
the
heavy
staining
of
oil
and
grease,
industrial
and
leather
facilities
typically
use
more
PCE
than
a
commercial
cleaners
that
use
similar
sized
and
age
of
equipment.
The
2
k:\
0154­
02­
010\
DCTM_
ARP.
wpd
higher
PCE
usage
in
these
facilities
is
the
result
of
more
PCE
being
retained
in
the
heavy
garments
even
after
an
extended
drying
cycle.
For
this
reason
the
industrial
and
leather
shops
often
have
drying
cycles
of
45
minutes
to
hour
and
half
compared
to
fifteen
minute
drying
cycles
for
commercial
facilities.
Of
the
fifteen
major
source
facilities,
the
four
top
PCE
users
are
industrial
facilities
cleaning
some
percentage
of
leather
and
heavy
work
gloves.
These
four
facilities
use
65%
of
the
total
PCE
of
all
the
major
sources.
The
commercial
operations
are
the
corner
neighborhood
dry
cleaner.
They
typically
clean
garments
from
the
public
like
pants,
shirts,

dresses,
comforters,
curtains
and
linens.
Most
of
the
27,000
area
source
facilities
are
commercial
dry
cleaners.
The
typical
commercial
dry
cleaners
often
do
not
have
processes
to
clean
leather
products.
As
a
result
they
out
source
these
products
speciality
leather
cleaning
shops.

2.0
NO
NEW
MAJOR
SOURCES
The
15
major
source
dry
cleaning
facilities
are
those
facilities
that
were
using
2100
gallons
(
or
1800
gallons
if
using
transfer
machines)
or
more
of
PCE
per
year
on
or
after
the
compliance
date
of
September
23,
1996
for
the
NESHAP.
Eight
of
15
major
source
facilities
are
not
currently
using
less
than
2,100
gallons
[
1800
gallons]
a
year,
however,
because
of
the
EPA
"
Once
In
Always
In"
policy,
these
facilities
are
still
considered
major
sources.

In
the
future,
the
only
major
sources
that
we
expect
to
see
are
the
existing
15
facilities.

Based
on
the
low
emission
rates
of
current
PCE
dry
cleaning
machines
and
the
typical
business
models
used
in
the
industrial
and
commercial
dry
cleaning
sectors,
it
is
unlikely
that
any
new
major
sources
will
be
constructed
or
that
any
existing
area
sources
will
become
major
sources
by
the
addition
of
new
equipment.
The
current
typical
business
model
for
major
source
facilities
is
picking
up
clothes
for
processing
within
a
250
mile
radius
of
the
facility
and
not
across
several
states,
this
limits
the
amount
of
potential
garments
facilities
can
service
(
Vantol,
2004).
Most
new
dry
cleaning
machines
have
fourth
generation
(
dry­
to­
dry
closed
loop
machines
with
refrigerated
condenser
and
carbon
adsorber)
emission
controls.
A
typical
new
fourth
generation
machine
can
clean
800
pounds
of
garments
per
gallon
of
PCE.
A
new
or
existing
source
using
this
type
of
equipment
would
need
to
clean
840
tons
of
clothes
to
exceed
the
major
source
threshold
of
2,100
gallons
[
2,100
gallons
*
800
lb/
gallon
*
1
ton/
2000
lb
=
840
tons].
3
k:\
0154­
02­
010\
DCTM_
ARP.
wpd
The
largest
dry
cleaning
facility
in
the
U.
S.
,
ALAC
Garment
Services,
dry
cleaned
893
tons
in
2001.
During
our
meeting
with
ALAC
on
November
19,
2002,
their
president
stated
that
the
cost
of
delivering
cleaned
garments
over
a
large
area
limits
the
size
of
industrial
dry
cleaners.

It
is
unlikely
that
a
facility
could
attain
ALAC's
size,
either
initially
or
with
growth
over
time,

especially
since
volume
in
both
the
industrial
and
commercial
sectors
has
been
declining.

No
new
commercial
facilities
are
expected
to
be
major
sources.
New
area
sources
allowed
to
install
third
generation
machines
(
dry­
to­
dry
closed
loop
with
refrigerated
condenser)

under
the
current
requirements
of
the
NESHAP,
would
need
to
clean
525
tons
of
clothes
to
exceed
the
major
source
threshold
of
2,100
gallons.
This
estimate
is
based
on
a
typical
performance
of
a
new
third
generation
machine
of
500
pounds
per
gallon
of
PCE
[
2,100
gallons
*

500
lb/
gallon
*
1
ton/
2000
lb
=
525
tons].

The
largest
commercial
dry
cleaning
source,
Bergmann's
Inc.,
dry
cleaned
390
tons
of
garments
in
2001.
We
do
not
anticipate
that
any
facilities
will
clean
as
much
as
525
tons
of
garments
per
year.
Several
dry
cleaning
chains
have
thirty
to
sixty
storefronts,
but
the
logistics
of
the
commercial
market
make
it
uneconomical
to
clean
clothes
from
a
large
network
at
a
single
location.
They
divide
up
the
drop
shops
to
send
their
clothes
to
be
processed
at
several
plants
instead
of
one
large
plant.
Therefore,
it
is
also
unlikely
that
a
new
facility
in
the
commercial
sector
using
third
or
fourth
generation
machines
would
exceed
the
major
source
threshold.
New
and
existing
commercial
dry
cleaning
sources
are
and
will
be
area
sources.

3.0
INDUSTRY
TRENDS
In
the
early
1990'
s
when
the
NESHAP
was
developed,
a
majority
of
the
dry
cleaning
machines
at
major
and
area
sources
were
vented.
Third
generation
(
non­
venting)
machines
were
gaining
popularity
among
major
and
area
source
dry
cleaners.
Fourth
generation
machines
were
just
becoming
available
and
few
facilities
had
these
machines.
Currently,
the
majority
of
the
national
population
of
machines
has
shifted
from
vented
machines
to
third
generation.
Table
1
shows
the
estimated
percent
distribution
of
dry
cleaning
machines
in
the
nation.
4
k:\
0154­
02­
010\
DCTM_
ARP.
wpd
Table
1.
National
Distribution
of
Machine
Types*

Machines
Estimated
National
Population
(
Percent)**

Transfer
2
Vented
5
Third
Generation
68
Fourth
Generation
25
*
Area
Source
Cost
Memorandum,
to
be
written
Sept
2004.
**
This
estimated
national
population
does
not
include
state
of
New
York,
all
of
their
facilities
are
required
to
have
machines
with
secondary
controls.

Even
though
the
trend
in
the
industry
has
been
to
replace
transfer
and
vented
machines
with
machines
with
better
emission
controls,
there
still
are
many
transfer
and
vented
machines
being
operated.
The
national
population
of
PCE
machines
is
30,000
(
27,000
facilities
multiplied
by
1.1
machines
per
facility),
2%
or
600
of
these
machines
are
transfer
and
5%
or
1500
are
vented
machines
still
being
used.
Of
the
2,100
transfer
and
vented
machines
still
in
operation,
only
two
of
those
are
major
sources,
using
vented
machines.
This
means
that
approximately
2,100
commercial
and
industry
area
sources
could
still
be
using
transfer
and
vented
machines
(
almost
10%
of
the
industry).
These
types
of
machines
are
relatively
large
emitters
of
PCE.
Almost
half
the
PCE
consumption
by
the
major
sources
is
from
the
two
facilities
with
vented
machines.
The
economic
life
of
dry­
to­
dry
machines
are
approximately
10
to
15
years.
The
economic
life
for
transfer
machines
is
5
years
longer
because
they
require
less
maintenance
to
keep
them
operating.

Facilities
that
are
still
operating
vented
and
transfer
machines
past
their
economic
life
generally
are
unwilling
or
unable
to
raise
the
capital
to
replace
their
machines
even
though
replacement
would
result
in
a
net
cost
savings.

The
majority
of
the
new
machines
sold
today
are
fourth
generation
machines.
Vented
and
transfer
machines
are
no
longer
sold.
Because
the
requirements
of
the
NESHAP
allowing
area
sources
to
install
third
generation
machines
and
because
of
the
vast
number
of
area
sources,
third
generation
machines
are
a
large
proportion
of
the
population
of
the
industry.
Many
area
source
dry
cleaners
are
buying
fourth
generation
machines
over
third
because
they
are
easier
to
operate,

use
less
PCE,
and
produce
less
hazardous
waste
than
third
generation
equipment,
but
also
because
they
recognize
that
fourth
generation
machines
are
likely
what
future
regulations
are
going
to
require.
Third
generation
machines
are
still
being
purchased.
A
machine
manufacturer
stated
that
70%
of
the
new
PCE
machines
sold
in
2000
were
4th
generation
and
by
2003,
nearly
all
of
the
PCE
machines
sold
were
fourth
generation
(
Firbimatic,
12­
17­
03).
New
York
and,
5
k:\
0154­
02­
010\
DCTM_
ARP.
wpd
beginning
in
2007,
California
require
fourth
generation
equipment
for
all
existing
major
and
area
sources.
Due
to
the
vast
number
of
area
sources
compared
to
major
sources,
the
majority
of
the
new
PCE
machines
sold
are
to
area
sources
to
replace
third
generation
machines.

The
newest
PCE
machine
technology
is
called
fifth
generation.
These
machines
have
a
PCE
analyzer
in
the
drum,
and
a
lock­
out
system
that
will
not
unlock
the
drum
door
until
the
PCE
concentration
falls
below
a
set
point,
typically
300
ppm.
This
technology
is
required
at
all
dry
cleaners
in
Germany.
No
major
source
dry
cleaners
in
the
United
States
utilize
this
technology.

A
Canadian
industrial
facility
uses
fifth
generation
machines
to
clean
leather
gloves,
aprons,
and
cotton
uniforms.
A
handful
of
area
source
dry
cleaners
in
the
United
States
use
fifth
generation
controls.
Fifth
generation
equipment
cost
approximately
$
12,000
more
than
fourth
generation
equipment
regardless
of
the
capacity
of
the
machine.

The
number
of
dry
cleaners
replacing
PCE
operations
with
alternative
technologies
is
growing.
Approximately
85%
of
all
dry
cleaning
machines
use
PCE.
The
remaining
15%
of
machines
used
other
dry
cleaning
solvents,
such
as
hydrocarbon
blended
solvents,
GreenEarth
®
,

liquid
CO
2
and
wet
cleaning
(
Area
Source
Cost
Memorandum,
Sept
2004).
The
percent
of
alternative
solvent
machines
has
been
growing
over
the
last
ten
years.
Just
about
five
years
ago
in
the
late
1990s,
the
percent
of
facilities
using
alternative
solvents
was
approximately
10%

(
National
Clothesline,
July
1999).
Currently
hydrocarbon
solvents
are
the
most
popular
alternative
solvent
among
dry
cleaners.
The
higher
percentage
of
dry
cleaners
using
alternative
technologies
have
been
influenced
by
cleaners
switching
to
avoid
the
current
PCE
regulations
and
others
because
of
the
threat
of
future
regulations.
In
addition,
some
commercial
property
owners
are
requiring
their
dry
cleaning
tenants
to
replace
their
PCE
machines
with
alternative
solvents
as
a
condition
to
renew
their
lease.
Commercial
building
owners
are
concerned
with
the
publicity
of
the
potential
health
risks
of
PCE
and
do
not
want
a
PCE
dry
cleaner
on
their
commercial
property.
The
property
owners
are
also
concerned
about
potential
future
remediation
of
contaminated
soil
and
ground
water.
Machine
manufacturers
estimate
that
20
to
50%
of
the
new
machines
purchased
are
alternative
solvent
technologies.

A
trend
developing
in
the
last
couple
of
years
is
for
industrial
dry
cleaners
to
switch
from
PCE
to
hydrocarbon
solvents.
These
dry
cleaners
are
switching
for
many
of
the
same
reasons
commercial
cleaners
are
switching,
but
mainly
because
of
the
potential
additional
PCE
regulations.
In
at
least
one
case,
these
facilities
have
chosen
Stoddard
solvent,
a
Class
II
6
k:\
0154­
02­
010\
DCTM_
ARP.
wpd
hydrocarbon
solvent
(
i.
e.,
lower
flash
point
of
100
to
139

F),
over
synthetic
hydrocarbon
solvents
like
DF­
2000,
a
Class
III.
A
solvent
(
i.
e.,
lower
flash
point
of
140
to
199

F).
Stoddard
solvent
is
more
attractive
to
the
industrial
cleaner
because
it
is
more
volatile,
thus
reducing
the
drying
time
compared
to
synthetic
hydrocarbon
solvents
and
because
of
its
cleaning
power
as
a
solvent
(
as
measured
by
kB
value).
Industrial
garments
(
i.
e.,
leather
and
heavy
cotton
gloves,
leather
aprons,

shop
rags,
etc.)
cleaned
with
PCE
require
extended
drying
time,
but
even
more
so
with
hydrocarbon
solvents.

Class
IIIA
Hydrocarbons,
followed
by
wet
cleaning,
are
the
most
popular
alternative
technologies
in
area
source
facilities.
A
recent
decision
by
several
states
to
switch
from
National
Fire
Protection
Association
(
NFPA)
codes
to
the
International
Building
Code
(
IBC)
has
slowed
the
growth
rate
of
hydrocarbon
machines.
Under
the
IBC
requirements,
hydrocarbons,
with
a
flashpoint
under
200

F
are
classified
as
flammable.
However,
it
is
possible
that
this
part
of
the
IBC
may
be
changed
or
local
waivers
of
it
may
become
more
common.

4.0
REFERENCES
Haiges,
Darrin,
Firbimatic.
Personal
Communication
with
Eric
Goehl.
Subject:
Population
Distribution
of
3rd
and
4th
generation
Machines.
December
17,
2003.

Memorandum.
Heaney,
Mike
and
Goehl,
Eric.
Eastern
Research
Group,
Inc.
to
Dry
Cleaning
Residual
Risk
Project
File.
Area
Source
Cost
Memorandum.
TO
BE
DEVELOPED
IN
SEPT,
2004.

Transfer
out,
But
perc
is
still
in.
National
Clothesline.
July
1999.

TCATA
Reports
2002
Perc
DryCleaning
Demand.
Textile
Care
Allied
Trades
Association.
July
2003.
<
http://
www.
TCATA.
org..

Vantol,
Jeff,
White
Tower.
Personal
Communication
with
Eric
Goehl.
Subject:
Maximum
Distance
to
Pick­
up
Garments
to
Process.
August
25,
2004.
