California Dry Cleaning Industry 

Technical Assessment Report 

Stationary Source Division 

Emissions Assessment Branch 

Release Date: February 2006 
State of California 

AIR RESOURCES BOARD

California Dry Cleaning Industry 

Technical Assessment Report 

Prepared by:

Mei Fong (Lead) 

Hafizur R. Chowdhury 

Michele Houghton 

Michelle Komlenic 

Sonia Villalobos 

Reviewed by:

Richard A. Boyd II, Manager, Emissions Evaluation Section 

Daniel E. Donohoue, Chief, Emissions Assessment Branch 

Robert D. Barham, Ph.D., Assistant Chief, Stationary Source Division 

Robert D. Fletcher, Chief, Stationary Source Division 

February 2006 
ACKNOWLEDGMENTS

We wish to acknowledge the participation and assistance of the following local air 

districts. 

 Bay Area Air Quality Management District 

 Mojave Desert Air Quality Management District 

 Santa Barbara County Air Pollution Control District 

 South Coast Air Quality Management District 

The ARB would like to acknowledge the assistance of the following individuals, 

agencies, and organizations for their participation and assistance: 

Monitoring and Laboratory Division, ARB Micheal Orbanosky 

Monitoring and Laboratory Division, ARB Angus Macpherson 

Office of Environmental Health Hazard Assessment Dr. James Collins 

Department of Health Services Dr. Julia Quint 

Sanitation District of Los Angeles County Ann Heil

Institute for Research and Technical Assistance Dr. Katy Wolf 

California Cleaners Association Sandra Giarde 

Blackburn’s Consulting & Training Bob Blackburn 

Halogenated Solvents Industry Alliance Stephen P. Risotto 

Urban & Environmental Policy Institute Peter Sinsheimer 

GreenEarth®

 Cleaning James E. Douglas 

ExxonMobil Chemical Arlean Medeiros 

Kelleher Equipment Supply, Inc. Kelly Kelleher Casares 

 
TABLE OF CONTENTS 

Section Page 

I. INTRODUCTION......................................................................................I-1 

A. Background ...................................................................................I-1 

B. Industry Characteristics.................................................................I-1 

II. DRY CLEANING TECHNOLOGIES .......................................................II-1 

A. Perchloroethylene Cleaning .........................................................II-1 

B. Hydrocarbon Solvent Cleaning.....................................................II-1 

1. DF-2000 Fluid.....................................................................II-2 

 2. Pure Dry®

..............................................................................II-2 

 3. Eco Solv®..............................................................................II-2 

 4. Shell Sol 140 HT...................................................................II-3 

 5. Stoddard Solvent..................................................................II-3 

C. Volatile Methyl Siloxane Cleaning ................................................II-3 

D. Rynex

 (Propylene Glycol Ether) Cleaning ..................................II-3 

E. Carbon Dioxide (CO2) Cleaning....................................................II-4 

F. Professional Wet Cleaning ...........................................................II-4 

G. Green Jet®....................................................................................II-5 

H. Emerging Technologies................................................................II-5 

 1. Cold Water Cleaning Systems..............................................II-5 

 2. Resolv Dry Cleaning System..............................................II-6 

 3. Impress Solvent..................................................................II-6 

 4. Hydroclene Fluids.................................................................II-6 

I. Flammability and Safety ...............................................................II-6 

III. EMISSION CONTROL AND VENTILATION TECHNOLOGIES............III-1 

 A. Emission Control Technologies ...................................................III-1 

 1. Primary Controls..................................................................III-1 

 2. Secondary Controls .............................................................III-2 

 3. Other Control Technologies.................................................III-2 

 B. Ventilation Technologies .............................................................III-2 

 1. Natural Ventilation ...............................................................III-3 

 2. Window Fans.......................................................................III-3 

 3. General Ventilation..............................................................III-3 

 4. Local Ventilation ..................................................................III-3 

 5. Partial Vapor Rooms ...........................................................III-3 

 6. Vapor Barrier Rooms ..........................................................III-4 
TABLE OF CONTENTS (continued) 

Section Page 

IV. CURRENT DRY CLEANING STATUS ................................................. IV-1 

A. Dry Cleaning Facility Survey Results.......................................... IV-1 

 1. Facility Survey Response and Analysis.............................. IV-1 

 2. Business Information.......................................................... IV-2 

 3. Operating Information......................................................... IV-3 

 4. Machine Information and Operating Schedule ................... IV-5 

 5. Facility Size ........................................................................ IV-8 

 6. Receptor Distance ............................................................. IV-9 

 7. Ventilation Type................................................................ IV-10 

 8. Maintenance Information .................................................. IV-11 

 9. Future Machine Purchase ............................................... IV-12 

B. Site Visit Results....................................................................... IV-13 

C. Machine Manufacturers Survey Results................................... IV-16 

D. Dry Cleaning Solvent Manufacturers Survey............................ IV-17 

E. Perc Solvent Distributors Survey Results ................................. IV-18 

F. Perc and DF-2000 Sludge Test Results ................................... IV-18 

G. Leak Detector Evaluation ......................................................... IV-19 

H. Emissions from Dry Cleaning Operations................................. IV-21 

V. POTENTIAL HEALTH IMPACTS .......................................................... V-1 

A. Perchloroethylene........................................................................ V-1 

1. Pollutant-specific Health Values .......................................... V-1 

B. Perc Alternatives ......................................................................... V-3 

 1. Hydrocarbon Solvent Cleaning (DF-2000, PureDry, 

 EcoSolv, Shell 140, Stoddard)............................................. V-3 

 2. Volatile Methyl Siloxane Cleaning ....................................... V-4 

 3. Rynex

 (Propylene Glycol Ether) ........................................ V-5 

 4. Carbon Dioxide Cleaning..................................................... V-5 

 5. Professional Wet Cleaning .................................................. V-6 

 6. Green Jet® .......................................................................... V-7 

 7. 1-Propyl Bromide................................................................. V-8 

C. Interim Health Values .................................................................. V-8 

VI. ENVIRONMENTAL IMPACTS.............................................................. VI-1 

A. Wastewater ................................................................................ VI-1 

B. Groundwater Contamination....................................................... VI-2 

C. Hazardous Waste....................................................................... VI-3 

D. Soil ............................................................................................. VI-4 
TABLE OF CONTENTS (continued) 

Section Page 

E. Flammability ............................................................................... VI-4 

F. Energy Usage............................................................................. VI-5 

G. Air Pollution ................................................................................ VI-6 

 1. Impacts on VOC Emissions and Global Warming .............. VI-6 

 2. Workplace Exposure .......................................................... VI-6 

VII. COST ESTIMATION ............................................................................ VII-1 

A. Machine Cost ............................................................................ VII-1 

B. Operating Cost .......................................................................... VII-3 

C. Leak Detector Cost.................................................................... VII-7 

D. Control Technology ................................................................... VII-7 

VIII. EFFICACY EVALUATION.................................................................. VIII-1 

A. Hydrocarbon Solvent Cleaning................................................. VIII-1 

B. Rynex

..................................................................................... VIII-2 

C. Water-based Cleaning Systems ............................................... VIII-2 

D. Carbon Dioxide Cleaning.......................................................... VIII-2 

E. GreenEarth

............................................................................. VIII-3 

IX. REFERENCES...................................................................................... IX-1 

APPENDICES

Appendix A: Dry Cleaning Facility Survey 

Appendix B: Dry Cleaning Site Visit Survey 

Appendix C: Machine Manufacturer’s Survey 

Appendix D: Standard Operating Procedure for the Determination of 

Tetrachloroethylene in Dry Cleaning Sludge by Gas 

Chromatography - FID 

Appendix E: Standard Operating Procedure for the Determination of 

 DF-2000TM in Dry Cleaning Sludge 

 by Gas Chromatography – Mass Selective Detector 

Appendix F: Sludge Sampling Results 
TABLE OF CONTENTS (continued) 

APPENDICES (continued)

Appendix G: OEHHA Memorandum 

Appendix H: Laboratory Evaluation of Leak Detectors 

Appendix I: Contact Information for Alternative Solvents 

Appendix J: Electricity Cost Calculations 

Appendix K: Summary of Comments 

Appendix L: Glossary and Acronyms 
LIST OF TABLES 

Table Title Page 

Table I-1 Statewide Estimates of Perc Dry Cleaning Operations .....................I-2 

Table I-2 Statewide Estimates-California Dry Cleaning Industry ......................I-3 

Table IV-1 Business Information...................................................................... IV-2 

Table IV-2 Summary of Business Hours .......................................................... IV-3 

Table IV-3 Comparison of Business Type........................................................ IV-3 

Table IV-4 Summary of Operating Information................................................. IV-4 

Table IV-5 Machine Information....................................................................... IV-6 

Table IV-6 Days of Machine Operation............................................................ IV-8 

Table IV-7 Summary of Receptor Distances.................................................. IV-10 

Table IV-8 Ventilation Information.................................................................. IV-11 

Table IV-9 Summary of Maintenance Information.......................................... IV-12 

Table IV-10 Summary of Future Machine Purchase ........................................ IV-13 

Table IV-11 Comparison of Amount of Co-location and Facility Size............... IV-14 

Table IV-12 Comparison of Distance to Receptors.......................................... IV-14 

Table IV-13 Comparison of Facility Ventilation ................................................ IV-16 

Table IV-14 Summary of Perc Usage .............................................................. IV-18 

Table IV-15 Summary of Perc and DF-2000 Sludge Tests .............................. IV-19 

Table IV-16 Summary of Leak Detector Evaluation ......................................... IV-21 

Table IV-17 Facility Survey Summary for Emission Analysis........................... IV-23 

Table IV-18 Emissions Comparison................................................................. IV-25

Table V-1 Adopted Health Values for Perc ...................................................... V-2 

Table V-2 Summary of Interim Health Values.................................................. V-8 

Table VI-1 Summary of Flash Points and Classification for Commonly 

 Used Solvents ................................................................................ VI-5 

Table VI-2 Estimated Monthly Electricity Usage ............................................. VI-6 

Table VI-3 Potential Health Impacts and Permissible Exposure Limit (PEL) ... VI-7 

Table VII-1 Summary of Machine Cost from Survey........................................ VII-1 

Table VII-2 Machine Cost Comparison for a Typical Dry Cleaning Facility ...... VII-3 

Table VII-3 Dry Cleaning Solvent Costs .......................................................... VII-4

Table VII-4 Average Machine Gas and Electricity Usage for Each 

 Dry Cleaning Process.................................................................... VII-5 

Table VII-5 Annual Cost Comparison for the First Five Years of a Typical 

 Size Dry Cleaning Facility.............................................................. VII-6 

Table VII-6 Comparison of Cost for Perc Concentration Detectors.................. VII-7 

Table VIII-1 Summary of KB and Surface Tension Values and Cleaning 

Performance of Dry Cleaning Solvents......................................... VIII-4 
LIST OF FIGURES 

Figure Title Page 

Figure IV-1 Machine Age .................................................................................. IV-6 

Figure IV-2 Machine Capacity........................................................................... IV-7 

Figure IV-3 Time of Machine Operation ............................................................ IV-8 

Figure IV-4 Distribution of Facility Area............................................................. IV-9 

Figure IV-5 Distribution of Facility Height .......................................................... IV-9 

Figure IV-6 Map of Facility Site Visit Locations ............................................... IV-15 
I-1 

I. INTRODUCTION 

A. Background 

An assessment of dry cleaning technologies was performed as part of the 

technical evaluation of the Airborne Toxic Control Measure for Emissions of 

Perchloroethylene from Dry Cleaning Operations (Dry Cleaning ATCM). The purpose of 

the assessment was to compare perchloroethylene (Perc) dry cleaning to the available 

alternatives and determine whether the Dry Cleaning ATCM, which was originally 

adopted in 1993, continues to be adequately protective of public health. The last 

technology assessment was conducted from 1991 to 1993 as part of the Air Resources 

Board’s development of the Dry Cleaning ATCM. This report details the dry cleaning 

technology assessment and compares some of the results to the earlier assessment. 

Information regarding the California dry cleaning industry was obtained from 

several surveys of the dry cleaning industry. This includes the types of machines being 

used, the types of machines that are available, and the amount of Perc being sold. The 

Dry Cleaning Facility Survey was developed by the California Air Resources Board 

(ARB), in cooperation with the California Cleaners Association, the Korean Dry 

Cleaners-Laundry Association, other industry representatives, and the local air districts. 

The purpose of the survey was to collect information from the dry cleaning facilities. 

The Machine Manufacturers Survey was used to collect information about cost and 

other machine information. The Perc Solvent Distributor’s Survey was used to collect 

information on the percentage of Perc that is used by the dry cleaning industry and to 

confirm Perc usage obtained from the dry cleaning facilities survey. Additionally, the 

Dry Cleaning Solvent Manufacturers Survey was used to obtain formulation information 

which was shared with the Office of Environmental Health Hazard Assessment 

(OEHHA). OEHHA used this information to provide input to the ARB regarding the 

health effects and toxicity of the solvents that are discussed in this report. 

ARB staff conducted site visits of dry cleaning facilities and conducted emissions 

testing to enhance our understanding of the California dry cleaning industry and the dry 

cleaning process. Staff visited over 100 facilities around the state collecting relevant 

information (e.g. distance to receptors, ventilation practices, and solvent usage). Our 

testing included collecting and testing sludge from Perc and DF-2000TM Fluid (DF-2000) 

dry cleaning facilities, evaluating the effectiveness of Perc detectors, and measuring 

Perc concentrations around Perc dry cleaning machines and other locations in the 

facilities. 

 

B. Industry Characteristics 

California dry cleaners are typically small businesses employing less than five 

employees, with over half of them employing two or less full time employees. They are 

usually independently owned and are often operated by the owner and/or their spouse. 

Over 50 percent of a facility’s income is from the dry cleaning of garments. Other 
I-2 

common sources of income include laundry and alteration. The industry is highly 

competitive; even though about half of the dry cleaners have been in operation for 

10 years or more, around 30 percent have been in the business for five years or less. 

Most facilities are open for business from Monday through Saturday 

There are about 5,040 dry cleaning facilities in the state. Over 95 percent of 

these facilities operate a single dry cleaning machine and over 82 percent of the dry 

cleaning machines use Perc as the solvent. There are three types of Perc dry cleaning 

machines in use: machines converted from vented to closed-loop (converted), 

closed-loop machines with primary control (primary), and closed-loop machines with 

both primary and secondary control (secondary). Over half of the machines in operation 

are primary machines and about a third of the machines are secondary machines. The 

percentage of converted machines is small. 

Based on extrapolation of the facility survey data, estimates of the Perc dry 

cleaning operations can be made. Table I-1 compares these estimates with those 

made in the early 1990’s during the ATCM rule development process. 

Table I-1. Statewide Estimates of Perc Dry Cleaning Operations 

 

Statewide Estimates 1991 Survey 2003 Survey 

Number of Perc dry cleaning machines1

5,310 4,670 

Pounds of materials dry cleaned annually2

258 million 256 million 

Pounds of materials dry cleaned using Perc annually2

247 million 214 million 

Gallons of Perc used3

1,100,000 378,000 

Gallons of Perc emitted3

742,000 222,000 

1. Values are rounded off to the nearest ten. 

2. Values are rounded off to the nearest million. 

3. Values are rounded off to the nearest thousand. 

As shown on Table I-1, there are about 4,670 Perc machines currently in 

operation statewide. This is an estimated 12 percent decrease from 1991. In addition, 

the amount of clothes cleaned by Perc machines has correspondingly decreased by 

approximately 13 percent. An interesting observation is that the amount of clothes dry 

cleaned annually has remained about the same. We believe this indicates an increase 

in the use of alternative dry cleaning processes. For statewide Perc emissions, the 

amount of Perc emitted is estimated to have decreased by about 70 percent after 

implementation of the Dry Cleaning ATCM. 

The types of alternative solvents used in 1991 included: Stoddard Solvent 

(Stoddard), CFC-113, and 1,1,1-Trichloroethane. And, as shown on Table I-1, about 96 

percent of the clothes dry cleaned used Perc. Currently, about 84 percent of the clothes 

dry cleaned use Perc; the second solvent of choice is DF-2000, a high flash point 

synthetic hydrocarbon solvent manufactured by ExxonMobil. Other alternative cleaning 

processes and cleaning solvents include: carbon dioxide (CO2) cleaning, water-based 

cleaning systems such as professional wet cleaning (wet cleaning) and Green Jet
I-3 

(Green Jet), GreenEarth

 (GreenEarth), RynexTM (Rynex 3), PureDry(PureDry), 

Stoddard, as well as other high flash point hydrocarbon solvents such as EcoSolv Fluid 

(EcoSolv) and Shell SOL 140 HT (Shell 140). Table I-2 summarizes the current 

technologies used by California dry cleaners. An analysis of these technologies, as well 

as other available technologies is presented in Chapter II. 

Table I-2. Statewide Estimates - California Dry Cleaning Industry1

 

Statewide Estimates Number2 Percent (%)3

Dry cleaning facilities 5,040 n/a 

Perc dry cleaning facilities 4,290 85 

Mixed facilities (Perc + Alternative) 190 4 

Non-Perc facilities 550 11 

 DF-2000 400 8 

 GreenEarth 90 2 

 Others (wet cleaning, Green Jet, PureDry, Rynex 3, 

 Stoddard, and other high flash point hydrocarbon 

 solvent) 

60 1 

1. Source: 2003 survey. 

2. Values are rounded to the nearest 10. 

3. Values are rounded to the nearest integer. 

 Wet cleaning and Stoddard facilities usually employ a transfer process that 

requires moving the material being cleaned from a washer to a dryer. The facilities that 

use DF-2000 and other available alternatives normally operate with a single closed-loop 

machine. Except for the machines that operate with Tonsil

 (a bleaching clay made of 

natural calcium bentonite material that is acid activated) and CO2 machines, most of 

these closed-loop machines operate with primary control and usually with a water 

separator and vacuum still. It is reported that the machines that operate with Tonsil

(Tonsil) can operate without a still (Kelleher, 2004). Tonsil has been in use for the last 

few years and cleaners typically use it in a 50 percent tonsil/ 50 percent diatomaceous 

earth blend (IRTA, 2005). Cost of alternative machines, with the exception of wet 

cleaning and Green Jet machines, are typically higher than Perc machines. However, 

other operational costs can be lower with non-Perc processes (see Chapter VII). 
II-1

II. DRY CLEANING TECHNOLOGIES 

This chapter provides some background and technical information regarding the 

dry cleaning technologies used in California. The economic details of these 

technologies are presented in Chapter VII. This chapter also briefly discusses some 

emerging dry cleaning technologies which are not fully commercially developed in 

California. 

A. Perchloroethylene Cleaning

 Perchloroethylene (Perc) is the most widely used dry cleaning solvent in 

California. Perc is also used in other industry sectors including degreasing operations, 

paints and coatings, and industrial and consumer products. The Airborne Toxic Control 

Measure for Emissions of Perchloroethylene from Dry Cleaning Operations (Dry 

Cleaning ATCM) currently permits the use of closed-loop, dry-to-dry machines when 

Perc is the solvent of choice. The vast majority of California dry cleaners are familiar 

with the operation of this technology. Vented and transfer machines have been phased 

out and no Perc dry cleaners should be using these systems at this time. 

Closed-loop, dry-to-dry machines are equipped either with primary controls 

(primary control machines) or with both primary and secondary controls (secondary 

control machines). Primary control machines feature a refrigerated condenser which 

cools the hot air exhaust from the drum to at least 45 degrees Fahrenheit (°F). This 

allows for the recovery of at least 50 percent more Perc than in older generation 

machines. The cooled exhaust stream is then reheated and returned back to the drum. 

The reheated exhaust helps to remove residual Perc from the clothes during the drying 

cycle. A secondary control machine typically features one or more carbon adsorber 

beds in addition to the refrigerated condenser. The carbon adsorber operates during 

the cool-down phase and can reduce the Perc concentration to less than 300 parts per 

million by volume (ppmv). During regeneration of the carbon beds (usually a fixed 

interval based on number of loads or manufacturer’s recommendation), recovered Perc 

is returned to the machine’s Perc storage tank. 

Many machines also feature an inductive door fan. This device, which draws air 

through the loading door and drum when the door is opened, is used to minimize the 

release of residual solvent vapor during unloading (after cool-down). Door locks, which 

prevent the door from being opened when the drum concentration exceeds a set point 

(normally 300 ppmv), may also be installed. 

B. Hydrocarbon Solvent Cleaning 

 All hydrocarbon solvents used in dry cleaning consist of aliphatic hydrocarbons, 

meaning they are straight-chained, branched or cyclic as opposed to aromatics, which 

contains stable carbon-ring structures called benzene rings. Hydrocarbon solvents are 

combustible. Inherent properties of petroleum-based solvents include high flammability 
II-2

(more detailed discussion of flammability is presented in Chapter VI), volatility, odor, 

and toxicity. Toxicity varies by compound; however, none of the petroleum-based 

solvents have been evaluated by the California Air Resources Board (ARB) for their 

potential to be toxic air contaminants (toxicity of various solvents is discussed in 

Chapter V). All of the solvents are volatile organic compounds (VOCs). The machines 

predominately used for petroleum solvents mentioned below are closed-loop machines 

equipped with primary control. 

 

 1. DF-2000

Fluid

DF-2000 Fluid (DF-2000) was introduced in 1994 by ExxonMobil as an 

alternative solvent to Stoddard and Perc. Currently, it is the most popular alternative to 

Perc. Consisting of C11 to C13 aliphatic hydrocarbons, it is a synthetic mix of isoparaffins 

and cycloparaffins (naphthenes) that boils between 185 and 211 degrees Centigrade 

(OEHHA, 2003). Machines designed for DF-2000 and other hydrocarbon solvents offer 

closed-loop, dry-to-dry operation. Most include a primary control device (refrigerated 

condenser) and offer computerized control. 

2. PureDry

PureDry

 (PureDry) was developed as a replacement for Perc. It is a blend of 

isoparaffinic hydrocarbon and a chemical additive produced by 3M. The mixture 

contains about 95 percent odorless mineral spirits. The odorless mineral spirits are a 

mixture of aliphatic hydrocarbons (C9 to C12). Mineral spirits can cause neurotoxicity, 

and eye and respiratory irritation at high concentrations. It also contains HFE-7200 (a 

mixture of ethyl perfluoroisobutyl ether and ethyl perfluorobutyl ether), FC-43 (perfluoro 

compounds of primarily 12 carbons), PF-5070 (perfluoro compounds of primary seven 

carbons), and PF-5060 (perfluoro compounds of primarily six carbons) (OEHHA, 2003). 

The flash point of PureDry is 350°F with a boiling point temperature of 298°F. The flash 

point of a solvent is the temperature at which vapor given off will ignite when an external 

flame is applied under specified test conditions. A flash point is defined to minimize fire 

risk during normal storage and handling. Flash points for all dry cleaning solvents range 

from 110°F to 350°F. 

3. EcoSolv

Chevron Phillips Chemical Company LP manufactures EcoSolv(EcoSolv). This 

dry cleaning fluid is 100 percent isoparaffin with carbon numbers ranging from C9

through C13. The manufacturer formulated this product by adding butylated 

hydroxytoluene at 10 parts per million (ppm) to act as an oxygen stabilizer. This solvent 

is a high purity aliphatic mixture with minimum in aromatics. The isoparaffin is a 

branched hydrocarbon that is also used for food processing, cosmetic and personal 

care formulations, and as a solvent for a number of industrial products. EcoSolv has a 

flash point between140°F and 200°F, and is classified as Class IIIA solvent. 

(ARB, 2004e) 
II-3

4. Shell Sol 140 HT 

Shell Sol 140 HT (Shell 140) is a high flash point hydrocarbon solvent. 

Shell 140’s flash point is 145°F. This solvent works well in closed-loop machines. 

5. Stoddard Solvent

Stoddard Solvent (Stoddard), a class of petroleum solvents, consists of a blend 

of C8 to C12 hydrocarbons and is similar to kerosene. Its flash point is 110°F. Stoddard 

contains small amounts of chemicals known to be carcinogenic but are not classified as 

toxic. Stoddard also contains benzene, which has been identified as a toxic air 

contaminant. It also gives off an irritating odor. 

C. Volatile Methyl Siloxane Cleaning 

 Decamethylcyclopentasiloxane (D5) or volatile methyl siloxane is an odorless, 

colorless liquid that has many consumer and industrial applications. D5 is used as an 

ingredient in a number of personal health and beauty products, including deodorants, 

antiperspirants, cosmetics, shampoos, and body lotions. It is also used as a dry 

cleaning solvent. 

D5 is present in the GreenEarth(GreenEarth) dry cleaning solvent. GreenEarth 

solvent is mostly being used in hydrocarbon machines and has a flash point of 170°F. 

Although, GreenEarth is used in some converted Perc machines, the manufacturer 

does not recommend this option. In order for Perc machines to be converted, the 

following assemblies must be installed by manufacturer: filtration system; temperature 

control sensors; pre-water separator filter; water separator; and electrical control panel. 

GreenEarth solvent is distributed by Dow Corning, General Electric, and Shin-Etsu. 

D. Rynex (Propylene Glycol Ether) Cleaning

Rynex(Rynex 3) is an organic and biodegradable solvent with low volatility and 

a high flash point (>200°

F) and is classified as a Class IIIB solvent. Rynex 3 is lighter 

than water and, therefore, floats on water after separation. It is a mixture of substituted 

aliphatic glycol ethers. It is also considered a VOC. 

Rynex 3 can be used in most hydrocarbon machines with some temperature and 

timing adjustment. Converting Perc machines to use Rynex 3 is not recommended by 

the solvent manufacturer. It is not an economically prudent exercise due to the 

differences in physical properties of Perc and Rynex 3. 
II-4

E. Carbon Dioxide (CO2) Cleaning 

Carbon dioxide cleaning (CO2) is a process that has been developed for use by 

commercial and retail dry cleaners. CO2 is a non-flammable, non-toxic, colorless, 

tasteless, odorless naturally-occurring gas that, when subjected to pressure, becomes a 

liquid solvent. The liquid CO2 cleaning machines have a configuration which is similar 

to a solvent or Perc machine. The system is closed loop and comes equipped with a 

cleaning chamber, storage unit, filtration, distillation, and lint trap. Washing, vapor 

recovery, and drying are all performed in the cleaning chamber. 

The CO2 machines pressurize the gas in a drum to between 700 and 800 pounds 

per square inch (psi). For comparison purposes, a fire extinguisher is at 800 psi and a 

home oxygen tank is at 2,400 psi. Liquid CO2 and detergent is circulated through the 

clothes via jets inside the chamber. The jets are placed such that fluid impact upon the 

clothes results in rotation. Next, the CO2 is pulled out to prevent the dirt from being 

re-deposited on the clothing. At the end of the cycle (35-40 minutes), the pressure is 

released and the CO2 returns to a gaseous state, with dirt and substances removed 

from the clothing (the dirt and debris end up in the bottom of the tank). Cooling and 

drying of the clothes occurs as the liquid CO2 evaporates. 

The CO2 used in this process is an industrial by-product from existing operations, 

primarily anhydrous ammonia (fertilizer) production. There is no net increase in the 

amount of CO2 emitted; therefore, this process does not contribute to global warming. 

CO2 is naturally occurring and is also used in other applications such as carbonating 

soft drinks. There are three manufacturers of CO2 equipment in the United States. 

F. Professional Wet Cleaning 

Professional Wet Cleaning (wet cleaning), an alternative to dry cleaning that was 

first introduced in 1991, is different than commercial laundering in several aspects. Wet 

cleaning uses computer-controlled washers and dryers with detergents that have been 

specially formulated for the process. Specialized equipment is used because ordinary 

washers and dryers lack the necessary control needed to ensure that garments are 

processed properly. Finishing equipment includes pressing and tensioning units. The 

tensioning units are used in dry cleaning industry to touch-up, stretch, reform, and finish 

the garments. 

Due to the high agitation during the wash and spin cycles, an ordinary washer 

can damage garments. However, the washers used in wet cleaning use a 

frequency-controlled motor to control the rotation of the wash drum. As a result, a 

gentle wash action is produced and smoother acceleration and deceleration can be 

created. The wash program software can determine the appropriate combination of 

time, water level, water temperature, extraction, and drum rotation when manual 

operation is not desired. Washers are also designed to mix water with cleaning agents 

prior to entering the drum. 
II-5

Wet cleaned garments must be carefully dried in preparation for finishing. Wet 

cleaning generally takes about 45 minutes from wash through drying, not including the 

finishing time. As with high drum agitation, prolonged tumbling in a dryer, or otherwise 

over drying clothes, can cause shrinkage. Ordinary dryers control the drying process 

based on time and temperature. The dryers used in wet cleaning are based on humidity 

and are able to end the cycle when the desired humidity level in the garments has been 

achieved. 

Wet cleaning systems use non-toxic, biodegradable detergents, which are 

approved for disposal into the sewer system. The detergents are designed to be pH 

neutral and incorporate agents which prevent the interlocking of fibers. Many stains, 

such as salts, sugars, and foods and drinks, are readily removed by the wet cleaning 

process. Wet cleaning can also clean oil-based stains with the use pre-spotting 

chemicals that are specifically designed for water-based cleaning. Wet cleaning 

systems may also be gentler on buttons and ornamental pieces on clothing. 

G. Green Jet

The Green Jet (Green Jet) machine cleans and dries garments in a single 

computer-controlled unit. The machine is designed to receive a full 45 pound load of 

garments. It then dehydrates the garments to remove humidity and reduce surface 

tension, which allows mechanical action and pulsating air jets to dislodge and remove 

non-soluble soil from the garments. This soil is then collected in a lint chamber. Next, a 

pre-determined amount of water-based cleaning solution is injected through air jet 

nozzles to re-hydrate the fabric. After about a pint of solution has been injected, heavy 

felt pads attached to the ribs and the cylinder absorb the soluble soil. After the cleaning 

process, the unit goes into a conventional dry cycle and then a cool-down cycle. 

H. Emerging Technologies 

 There are four emerging technologies which are expected to be readily available 

to the dry cleaning industry within the next few years. These technologies are: 1) Cold 

Water Cleaning Systems; 2) the ResolveTM Dry Cleaning System; 3) the ImpressTM

Solvent, and 4) Hydroclene Fluids. 

1. Cold Water Cleaning Systems

 Cold water cleaning systems (washer and dryer) can wash and dry all fabrics, 

including fine fabrics. Suntech Company, Ltd. and By-For The Cleaners, Inc. are 

manufacturers of cold water cleaning systems. The product literature states that the 

system uses 100 percent water and biodegradable detergents to clean garments. 

Garments are washed in chilled water which ranges in temperature from 36°

F to 39°F. 

The use of chilled water is expected to minimize shrinking and may leave the use of 

tensioning equipment at the discretion of the dry cleaners. (ARB, 2004f) 
II-6

2. Resolve Dry Cleaning System

 Resolve (Resolve) is a new dry cleaning technology that uses dipropylene 

glycol normal butyl ether (DPNB). DPNB is a solvent which has been commonly used 

for more than 20 years in consumer products. R. R. Street, who is developing this 

technology, claims that extensive exposure studies have shown no known adverse 

health effects. According to the product literature, the Resolve system is able to take 

advantage of the low volatility of DPNB and uses liquid CO2 in the same equipment to 

extract the DPNB from garments without the use of heat. The garments can then dried 

by depressurizing the system to a gaseous state. Resolve is considered a VOC. 

(ARB, 2004g) 

3. Impress Solvent

Impress (Impress) dry cleaning solvent is a new propylene glycol-ether-based 

solution created by Lyondell Chemical Company. This solvent is readily biodegradable 

and compatible with hydrocarbon machines. According to the manufacturer, the 

solvent is gentle on fabrics. Impress has a flash point of 190°F and is classified as a 

Class IIIA solvent. As with any hydrocarbon or glycol ether, Impress is considered a 

VOC. According to Lyondell Chemical Company, Impress dry cleaning solvent is of 

low acute toxicity by oral and dermal (skin) exposure. Further tests for toxicity 

assessments are underway. (ARB, 2005e; ARB, 2005f) 

4. Hydroclene Fluids 

 Hydroclene is a mixture of normal-, iso-, and cyclo-paraffins. It is a complex 

solvent with the ability to dissolve a broad range of stains. It is a clear liquid with a 

boiling point 368°

F and a flash point of 145°F. Hydroclene is owned by Caled Chemical 

but the product is manufactured by Shell Chemical. (ARB, 2005f) 

I. Flammability and Safety 

 Dry cleaners should be aware of the flammability and safety issues of all the 

technologies described above, especially for converted machines. Dry cleaners are 

encouraged to consult with machine manufacturers to determine if a converted machine 

is able to operate safely with the solvent of choice. The flammability details and the 

summary of flash points and classification for various commonly used solvents are 

presented in Chapter VI, Table VI-1. Detailed information on products, technical data, 

as well as material safety data sheet (MSDS) are available by contacting the 

manufacturers. Appendix I lists the alternative solvents manufacturers contact 

information. 
III-1

III. EMISSION CONTROL AND VENTILATION TECHNOLOGIES 

 

This chapter briefly describes emission control and ventilation technologies. In 

dry cleaning operations, the majority of solvent is lost either through emissions to the 

atmosphere or via waste products. Furthermore, with perchloroethylene (Perc), a very 

small amount is also retained in clothes (relative to the total Perc emitted from dry 

cleaning operations). Some of the fugitive emissions can be controlled by using proper 

emission control and ventilation technologies to further reduce or capture emissions. 

 

A. Emission Control Technologies 

 Over the past several years, the use of Perc recovery devices has become 

common in the dry cleaning industry because of economic considerations, 

environmental concerns, worker exposure concerns, and regulatory actions. Emission 

reduction from the dry cleaning industry can be attained through the use of proper 

operating practices and control equipment. These greatly increase the amount of 

solvent being recycled while at the same time minimize the solvent loss to the 

atmosphere. Housekeeping measures include promptly repairing any worn or cracked 

gaskets, covering all solvent and waste containers, identifying and repairing any leaking 

equipment, and removing any lint build-up from the steam or water coils. Available 

control devices such as carbon adsorbers, refrigerated or chilled water condensers, and 

distillation units have proven to be very effective for reducing emissions and recovering 

the solvent for reuse. 

 

1. Primary Controls

Primary control systems operate during the heating and cool-down phases of the 

drying cycle. They are designed such that they neither exhaust to the atmosphere or 

workroom nor generate additional solvent-contaminated waste water (where 

applicable). Today, the most commonly used primary control device is the refrigerated 

condenser. In the past, carbon adsorbers and polymeric vapor adsorbers (a largely 

unproven technology) were also considered but could not compete with the overall 

efficiency of the refrigerated condenser. 

 Refrigerated condensers operate throughout the drying cycle, in which 

solvent-laden air is continually recirculated through the condenser. The condenser 

recovers both the solvent and water vapors from the air stream, sending a liquid solvent 

and water mixture to a water separator. The solvent recovered by the water separator 

then goes to the solvent storage tank. During the drying cycle, the air stream circulates 

past the refrigerated condenser, is reheated by the heating coils, circulates through the 

drum evaporating more solvent from the materials, and then flows through the 

condenser again where the solvent is recovered. (ARB, 1996) 

 In some hydrocarbon systems, the refrigeration unit is divided into separate 

segments for simplified maintenance and reduced downtime. The compressor, 
III-2

refrigeration coil, and heat-exchange coil can be individually serviced without removing 

the entire system. Sealed coils plus quick disconnects prevent Freon gas discharge. 

The refrigerated condenser keeps the temperature low during the drying cycle. 

2. Secondary Controls

A significant source of solvent emissions from closed-loop machines is from 

opening the drum at the end of the drying cycle to remove materials. For example, the 

concentration of Perc in the drum at the end of the drying cycle can be as high as 

8600 parts per million by volume (ppmv) (ARB, 1993). The operation of a secondary 

control device (typically a carbon adsorber - activated carbon bed contained in a 

housing), which operates in series with a refrigerated condenser, can further reduce 

solvent vapor concentrations in the drum and, therefore, reduce fugitive emissions and 

solvent consumption. Secondary control devices are activated at the end of the cool 

down step before the machine door is opened. These devices route solvent vapors 

from the drum and button and lint traps through a vapor adsorber, which strips solvent 

vapors from the air. In order to keep operating efficiently, the carbon must be 

periodically regenerated. The regeneration process typically uses heat to strip and 

recover the adsorbed solvent. This desorption process usually occurs after a specific 

number of loads or according to the manufacturer’s recommended schedule. 

(ARB, 1996) 

The Airborne Toxic Control Measure for Emissions of Perchloroethylene from Dry 

Cleaning Operations (Dry Cleaning ATCM) requires that closed-loop machines with 

secondary control systems reduce the concentration of Perc in the drum to less than 

300 ppmv at the end of the drying cycle. Based on source test results submitted to the 

California Air Resources Board (ARB) for the approval of the secondary control 

systems, some systems can reduce the Perc concentration to below 100 ppmv. There 

are no similar statewide requirements for other solvents. 

3. Other Control Technologies

Inductive door fans may be installed to further reduce fugitive emissions. This 

device, which draws air through the loading door and drum when the loading door is 

opened, is also beneficial in protecting the machine operator from residual solvent vapor 

during unloading. The inductive door fan may also be paired with a regenerative carbon 

canister. 

B. Ventilation Technologies

Ventilation at dry cleaning facilities is implemented in several different ways. 

Ventilation is important as it affects the dispersion of solvent vapors and other airborne 

compounds in the facility which in turns impacts the potential health risk to nearby 

residences and businesses. In many cases, the type of ventilation system found at a 

facility is a function of its construction. The facility owner most likely had little or no 

input into the design and construction of the ventilation system. Newer facilities tend to 
III-3

have more aggressive (or “active”) systems compared to the relatively passive 

implementations in older facilities. 

1. Natural Ventilation

Many facilities do not have active ventilation systems. This means that solvent 

vapors, such as Perc, are emitted from doors, windows, roof vents, and other openings 

throughout the facility. Natural ventilation depends upon wind and convective forces to 

move air and is typically considered the least effective. 

 

2. Window Fans

 Window fans or wall fans are high flow rate propeller type fans that are installed 

vertically in a wall (window-type-opening). The air is exhausted horizontally, typically 

near ground level. These also provide an improvement to a facility with only natural 

ventilation. 

3. General Ventilation

General ventilation systems typically have one or more large capacity fans on the 

roof of the facility. Capture efficiency depends on the air exchange rate inside the 

facility and is a function of the fan air flow rate and the size of the facility. General 

ventilation is considered an upgrade from natural ventilation. 

4. Local Ventilation

Local ventilation is a phrase used to describe a ventilation system with a high 

capacity fan, exhaust stack, and physical apparatus/structure (fume hoods, shrouds, 

flexible walls, vertical plastic strips) near the dry cleaning machine. This system is 

designed to capture fugitive emissions. Emissions are then exhausted through a stack 

on the roof of the facility. Fume hoods typically have plastic curtains on the sides (or a 

combination of walls and curtains) to minimize cross-flow drafts and provide better 

capture of fugitive emissions. 

5. Partial Vapor Rooms

A Partial Vapor Room (PVR) encloses the back of a dry cleaning machine in a 

small room with the front panel and loading door exposed for convenient loading and 

unloading. As a result, PVRs are able to more effectively capture fugitive emissions 

from leaks and maintenance activities when compared to local or general ventilation 

systems. Maintenance doors are normally closed and can be equipped with a 

self-closing device or alarm. Additionally, any windows are typically constructed of 

Plexiglas or tempered glass (for safety reasons). PVRs are typically used in co-located 

situations such as multi-story commercial buildings, mixed-use (residential/commercial) 

buildings, and shopping centers. 
III-4

6. Vapor Barrier Rooms

 Improving on partial vapor rooms, vapor barrier rooms (VBR) are the most 

efficient vapor capture systems. A VBR is able to restrict the diffusion and transport of 

solvent vapors that escape from a dry cleaning machine because a ventilation fan 

collects virtually all the vapors and exhausts them through a stack above the building. 

The door(s) to vapor barrier rooms are normally equipped with a self-closing device. 

Design features may vary, but normally include a “swinging” design that opens both 

ways or a sliding door. Additionally, any windows are typically constructed of Plexiglas 

or tempered glass (for safety reasons). VBRs are currently required for co-residential 

dry cleaning facilities in the San Francisco Bay Area and for all dry cleaners in 

mixed-use buildings in the State of New York. 
IV-1 

IV. CURRENT DRY CLEANING STATUS 

Current dry cleaning status was assessed based on several surveys, site visits of 

dry cleaning facilities, and emission testing. This chapter discusses the procedures 

used, and the results of the surveys, site visits, and emission testing. 

A. Dry Cleaning Facility Survey Results 

The Dry Cleaning Facility Survey (Facility Survey) was designed to collect 

information from the dry cleaning facilities. Many questions were asked on the Facility 

Survey to gather information concerning: operating information, facility information, 

potential future machine purchase/replacement, machine(s) type, solvent usage, waste 

produced, and maintenance information. Because of the large percentage of Korean 

dry cleaners, the Facility Survey and the cover letter were also translated into Korean. 

The Facility Survey and the cover letter are shown in Appendix A. 

1. Facility Survey Response and Analysis

A mailing list of dry cleaning facilities was compiled based on listings from Dun 

and Bradstreet and the local air districts. The lists were combined and duplicate 

addresses were deleted. With the help of Antelope Valley Air Pollution Control District 

(APCD), Mojave Desert Air Quality Management District (AQMD), and Ventura County 

APCD, over 6,300 Facility Surveys were sent in September 2003. The returned 

Facility Surveys were checked for address accuracy via yellow pages on the Internet. 

When needed, the facilities were called to verify address and/or if they were a dry 

cleaner. Where incorrect addresses were found, it was corrected and the 

Facility Surveys were mailed out again. Where the address did not exist, or there was 

currently not a dry cleaner at the address, that address was deleted from our database. 

In all, around 5,800 Facility Surveys were delivered and the response rate was 

32 percent. There were 265 drop off or agency shop returns. The number of 

Facility Surveys returned from dry cleaning facilities with dry cleaning machine(s) 

on-site was 1,634. Assuming the 14 percent proportion of drop off shops to dry 

cleaning plants is the same for those that did not return the Facility Survey, there are 

about 5,040 dry cleaning plants and 816 drop off shops in the State. 

During early 2004, the completed Facility Surveys were reviewed to see if they 

were from drop off shops or if they were from dry cleaners that operate machine(s) 

on-site (dry cleaning plants). The drop off shop returns were compiled and accounted 

for while the Facility Surveys from dry cleaning plants were reviewed for completeness. 

The facility operators or owners were contacted as necessary to obtain missing data, or 

to clarify the information submitted. Information obtained from the dry cleaning plants 

was then entered into a database. Each database entry was compared with the original 

Facility Surveys for accuracy. During survey analysis, the Facility Survey results were 

compared with site visit results. In most cases, the site visit results were reasonably 

similar to the Survey results. 
IV-2 

2. Business Information

Dry cleaners in California are mostly small businesses employing less than five 

employees. After equating 40 part-time hours worked by part-time employees to one 

equivalent full time employee, it is estimated that over half of the dry cleaners employ 

two or less equivalent full time employees. Dry cleaners are usually independently 

owned and often are operated by the owner and/or the spouse. Approximately 

40 percent of the dry cleaners gross less than 100,000 dollars annually, and, in general, 

income from dry cleaning constitutes 50 percent or more of their income. Other 

common sources of income include laundry and alteration. The industry is highly 

competitive; even though almost half of the facilities have been in operation for ten 

years or more, about a third have been in business for less than five years. Those who 

are in business for less than five years include both newly opened facilities and new 

owners of existing facilities. A summary of the discussed business information is shown 

in Table IV-1. 

Table IV-1. Business Information 

Years Owned Facility Percent1

< 1 7 

≥ 1 and < 5 25 

≥ 5 and <10 19 

≥ 10 and < 20 37 

≥ 20 12 

Business Status Percent1

Independently Owned 98 

Chain Operation 1 

Franchise 2 

Annual Receipts From Total Operation Percent1

Less than $100,000 40 

$100,000-$500,000 55 

$500,000 – above 5 

Percent Annual Receipts From Dry Cleaning Only Percent1

Less than 25% 7 

25-50% 18 

50-75% 48 

More than 75% 27 

Number of Equivalent Employees2 Percent1

≤ 2 57 

> 2 and ≤ 3 14 

> 3 and ≤ 4 8 

> 4 and ≤ 5 5 

> 5 16 

1. Values are rounded off to the nearest integer and may not add up to 100. 

2. Equivalent Employees include both full-time and part-time workers. 
IV-3 

During discussions at a workgroup meeting, it was noted that practically all dry 

cleaning facilities are open from Monday through Friday (ARB, 2003). Our 

Facility Survey results showed the same information. Most of the facilities open at 

7:00 AM in the morning and close between 6:00 PM and 7:00 PM in the evening from 

Monday through Friday. Our Facility Survey also showed that most (96 percent) of the 

facilities are open for business on Saturdays, but closed on Sundays. The business 

hours are summarized in Table IV-2 below. 

 Table IV-2. Summary of Business Hours 

Business Hours Percent1

Monday through Friday - Open 100 

Saturdays – Open 96 

Saturdays – Closed 4 

Sundays – Open 4 

Sundays – Closed 96 

 1. Values are rounded off to the nearest integer. 

Most dry cleaning facilities are plants where the material that is dry cleaned 

include clothing, curtains, sleeping bags, blankets, comforters, and leather goods 

(ARB, 1993a). Other business types make up less than five percent of the total and 

include: industrial dry cleaners, nonprofit organizations, and hotels/motels. This is 

similar to the findings of the survey the California Air Resources Board (ARB) conducted 

in 1991 (1991 Survey). A comparison of the business types obtained from the 1991 

Survey and the current, 2003 Dry Cleaning Facility Survey, is shown in Table IV-3. 

Table IV-3. Comparison of Business Type

Business Type 2003 Dry Cleaning 

Facility Survey 

(Percent)1

1991 Survey 

(Percent)1

Plant/Retail 96 96 

Industrial <1 1 

Government <0.5 1 

Nonprofit <0.5 <0.5 

Hotel/Motel <0.5 1 

Other 3 0 

 1. Values are rounded off to the nearest integer unless they are less than 1 and may not add up to 100. 

 3. Operating Information

The majority of the dry cleaning facilities operate a single dry cleaning machine. 

When considering the number of facilities that have more than one machine, the ratio is 

1.091 machines per facility. Therefore, there are about 5,500 dry cleaning machines in 

California. Most of these dry cleaning machines use Perchloroethylene (Perc) as the 

solvent. 
IV-4 

Besides Perc, the second solvent of choice is DF-2000TM Fluid (DF-2000), a high 

flashpoint, synthetic hydrocarbon solvent manufactured by ExxonMobil. Other 

alternative solvent/processes include: PureDry

(PureDry), GreenEarth(GreenEarth), 

RynexTM (Rynex 3), carbon dioxide (CO2) cleaning, water-based cleaning systems, such 

as Professional Wet Cleaning (wet cleaning) and Green Jet

(Green Jet), Stoddard, as 

well as other high flashpoint hydrocarbon solvents, such as EcoSolv

 Fluid (EcoSolv) 

and Shell Sol 140 HT (Shell 140). Wet cleaning and Stoddard usually employ a transfer 

process, while the facilities that use DF-2000 and other available alternatives normally 

operate with a closed-loop machine. Except for CO2 machines and machines that 

operate with Tonsil, most of these closed-loop machines operate with a refrigerated 

condenser, a water separator and vacuum still. A summary of the operating information 

is listed in Table IV-4. 

Table IV-4. Summary of Operating Information 

Number of Dry Cleaning Machines Percent of Facilities1

1 92 

2 8 

More than 2 < 1 

Solvent Type Percent of Machines1,2

Perc 85 

DF-2000 8 

Rynex 3 0 

Stoddard < 0.5 

GreenEarth 2 

Water (Professional Wet Cleaning) 3 

Water (Green Jet) < 0.5 

PureDry < 0.5 

EcoSolv 0 

Liquid CO2 < 0.5 

Other < 1 

Separator Water Treatment Method Percent of Entry1

Wastewater treatment Unit 63 

 Evaporator 48 

 Atomizer 7 

 Liquid Discharge 2 

Collected by waste hauler 26 

Discharge to sewer < 1 

Used in cooling tower 2 

Used to generate steam 5 

1. Values are rounded off to the nearest integer unless they are less than 1 and may not add up to 100. 

2. Values added to over 100 because of multiple entries per facility.

As shown on Table IV-4, about three percent of the facilities use wet cleaning. 

This value was based on verification of the input on the Facility Survey. After calling 

20 of the facilities that checked that they had wet cleaning on-site, it was found that a 

large percentage thought the term wet cleaning meant laundry and the Facility Survey 

result was adjusted accordingly. Currently, there are 37 dedicated wet cleaning 
IV-5 

facilities and 43 facilities that use wet cleaning together with another type of dry 

cleaning process (mixed shops) in the South Coast AQMD (ARB 2005c). Facilities that 

use wet cleaning outside of the South Coast AQMD are mostly mixed shops. 

In addition, as shown on Table IV-4, the Facility Survey indicated that two 

percent of facilities use GreenEarth. This equates to about 100 facilities and is lower 

than the 146 facilities as of January 2005 that was submitted to ARB by GreenEarth. 

Because the Facility Survey was sent out in 2003, the difference in number may reflect 

an increase in the number of GreenEarth facilities since the Survey was taken, or it 

could be due to uncertainties associated with the Facility Survey. None of the facilities 

that responded to the Facility Survey use the solvents Rynex 3 and EcoSolv. Currently, 

we know that Rynex 3 is being used by two facilities in California. In addition, Chevron 

Phillips notified ARB that EcoSolv is being used by over 30 percent of the high 

flashpoint hydrocarbon users in California (Chevron Phillips, 2005). 

Also shown on Table IV-4 is the method of separator water treatment being used 

by the facilities. Besides water-based cleaning systems and CO2 cleaning, dry cleaning 

machines usually operate with a water separator, which generates wastewater. 

Because separator water from a Perc dry cleaning machine contains Perc, it must be 

handled properly. The two most popular methods of separator water treatment are the 

use of a waste water treatment unit and the hiring of a waste hauler. 

Currently, there are three types of wastewater treatment units: evaporator, 

atomizer, and liquid discharge. The categories specify the method of waste effluent 

elimination, i.e. evaporators would eliminate the waste effluent via evaporation, 

atomizers via atomization, and liquid discharge via discharge as a liquid. According to 

the Facility Survey, a majority of the dry cleaning facilities (63 percent) have a 

wastewater treatment unit on-site, with a majority of these facilities using an evaporator. 

A significant portion (26 percent) of facilities have their wastewater collected by a waste 

hauler. There is also a small percentage of dry cleaners (less than one percent) who 

discharge their wastewater into the sewer, which is not allowed if they are using a Perc 

machine. On closer look of these dry cleaners, they are either new facility operators or 

operate one of the alternative dry cleaning processes. 

4. Machine Information and Operating Schedule

A summary of machine information is shown on Table IV-5. There are four types 

of dry cleaning machines in use: transfer machines, machines converted from vented to 

closed-loop (converted), closed-loop machines with primary control (primary), and 

closed-loop machines with both primary and secondary controls (secondary). Transfer 

machines in use today are for wet cleaning or for cleaning with hydrocarbon solvent, 

mainly Stoddard. Wet cleaning machines may either be transfer or closed-loop. The 

percentage of converted machines, about 2 percent, is small. 

As shown on Table IV-5, about 60 percent of the machines in operation are 

primary machines and about a third of the machines are secondary machines. The 
IV-6 

median capacity of the machines is 40 pounds (lbs). The average age of the machines 

surveyed is 8 years, and most of them were bought new. 

Table IV-5. Machine Information 

Machine Information 

Average Age (years) 8 

Bought New (percent) 89 

Bought Used (percent) 11 

Median Rated Capacity (lbs) 40 

Machine Type Percent1

Transfer 1 

Primary Control 62 

Secondary Control 28 

Converted (vent to no-vent) 2 

Wet Cleaning 2 

 1. Values are rounded off to the nearest integer unless they are less than 1 and may not add up to 100.

The machine age and capacity were grouped and compared by machine type as 

well as solvent types. When comparing machine age of the three types of Perc 

machines (converted, primary and secondary machines), there is a trend of lowering in 

age with the progression of machine types. The average age of Perc converted 

machines is 16 years, and it is six years older than that of Perc primary machines. The 

average age of Perc primary machines is 10 years and it is 6 years older than that of 

Perc secondary machines. In general, the machine age of the alternatives is lower than 

that of the Perc machines. The machine age comparison is shown in Figure IV-1 below. 

As shown in Figure IV-1, the age of DF-2000 machines, with an average of 2 years is 

2 years newer than that of the Perc secondary machines. 

 Figure IV-1. Machine Age 

Percent (%)

Age (Year)

0 10 20 30 40 50 60 70 80 90 100

0

5

10

15

20

25

30

Perc Converted

Perc Primary

Perc Secondary

DF-2000
IV-7 

The machine capacity is shown in Figure IV-2. The median machine capacity for 

each of the machine type plotted can be obtained from Figure IV-2 by looking at the 

capacity of that machine type that corresponds to 50 percent on the x-axis. The 

distribution of capacity for the converted machines roughly follows that of the Perc 

primary machines at below 40 percent and then of the Perc secondary machines up to 

about 85 percent. There is a slight increase in capacity when comparing Perc 

secondary machines to Perc primary machines; the median capacity for Perc secondary 

machines is 45 pounds while that for the Perc primary machines is 40 pounds. When 

comparing DF-2000 machines, they are generally slightly larger than the Perc 

secondary machines. The DF-2000 machines have a median capacity of 50 pounds. 

Figure IV-2. Machine Capacity 

Based on time of machine operation, the operation duration is about six 

hours each day for five or six days of the week. The machine operation start and 

end times are shown on Figure IV-3. As shown on Figure IV-3, although 

machine start time varies, around 80 percent of the facilities start machine 

operation by 8:00 AM; therefore, about 20 percent of the facilities start machine 

operation after 8:00 AM. Correspondingly, around 80 percent of the facilities 

stop machine operation at or before 3:00 PM. 

The machine operation hours discussed above reflect a majority of the dry 

cleaning business. Usually, processing of the garments immediately follows 

machine operation during the early part of the day because it involves steam 

presses which generate heat. One noted exception is wet cleaning. Because 

clothing from the wet cleaning process may not be processed right after it comes 

Percent (%)

Machine Capacity (lbs)

0 10 20 30 40 50 60 70 80 90 100

20

30

40

50

60

70

80

90

100

Perc Converted

Perc Primary

Perc Secondary

DF-2000
IV-8 

out of the machine, the machine operating time may be varied to allow for morning 

processing of the garments. 

 Figure IV-3. Time of Machine Operation

The number of days of machine operation in a week is shown on Table IV-6. As 

shown on the table, the majority of the facilities operate their machine(s) either five or 

six days per week. There is 55 percent (over half) of the facilities that operate their 

machines for five days during the week and 39 percent of the facilities that operate their 

machines for six days. The remaining facilities, about six percent, operate either seven 

days or less than five days. 

Table IV-6. Days of Machine Operation 

Number of days per week Percent1

5 days 55 

6 days 39 

Others 6 

 1. Values are rounded off to the nearest integer unless they are less than 1.

5. Facility Size

One of the tools that are used to estimate potential health impacts at dry cleaning 

facilities is air dispersion modeling. Information needed for dispersion modeling 

includes physical dimensions of the facilities, as well as emission estimates and 

emission release parameters. Information on facility area and height were obtained 

from the Facility Survey. 

6:00 AM

8:00 AM

10:00 AM

12:00 PM

2:00 PM

4:00 PM

6:00 PM

8:00 PM

0 10 20 30 40 50 60 70 80 90 100

Percent of Facilities (%)

Time

Start Time

End Time
IV-9 

The average area of the facilities is 1,900 square feet (sq. ft.), and the average 

height is 14 feet (ft.). The median facility area is 1,600 sq. ft., and the median facility 

height is 12 ft. Plots of the distributions of facility area and facility height are shown in 

Figures IV-4 and IV-5 below. As shown on Figure IV-4, about 10 percent of the dry 

cleaning facilities have facility areas that are under 1,100 sq. ft; therefore, about 90 

percent of the dry cleaning facilities have facility areas that are over 1,100 sq. ft. Also, 

as shown on Figure IV-5, about 50 percent of the dry cleaning facilities have heights 

that are lower than 12 ft; therefore, about 50 percent of the dry cleaning facilities have 

facility heights that are higher than 12 ft. 

Figure IV-4. Distribution of Facility Area Figure IV-5. Distribution of Facility Height 

6. Receptor Distance

Information on whether there are people living above or next to a dry cleaning 

facility (co-location information) and receptor distances to facilities were obtained from 

the Facility Survey. The type of receptors included businesses, residences, schools, 

day care facilities, hospitals, and senior communities. This information helps to 

characterize the location of the facilities and will be considered during risk assessment. 

A summary of receptor distances is shown on Table IV-7. 

 As shown on Table IV-7, about two percent of the facilities are co-located, with 

about one percent having people living next to and one percent having people living 

above the dry cleaning facilities. Also, over half of the facilities are within 20 ft. of the 

nearest business indicating that many facilities are most likely located in strip malls. In 

contrast, about four percent of the facilities are within 20 ft. of the nearest resident, and 

about 85 percent of the facilities are over 50 ft. from the nearest resident. The number 

of facilities that are less than 100 ft. away from schools, day care facilities, hospitals, 

and senior communities is two percent or less. 

Percent of Facilities (%)

Facility Area (sq. ft.)

0 10 20 30 40 50 60 70 80 90 100

0

2,000

4,000

6,000

8,000

10,000

Percent of Facility (%)

Facility Height (ft)

0 10 20 30 40 50 60 70 80 90 100

0

15

30

45

60

75
IV-10 

Table IV-7. Summary of Receptor Distances1

Information on Co-location Percent of All Facilities 

People live in building (above and next) 2 

Above building 1 

Next to building/facility 1 

Distance of Nearest Business Cumulative Percent 

≤ 20 feet 56 

≤ 50 feet 70 

≤ 100 feet 77 

≤ 500 feet 83 

Distance of Nearest Residence Cumulative Percent 

≤ 20 feet 4 

≤ 50 feet 15 

≤ 100 feet 28 

≤ 500 feet 63 

Distance of Nearest School Cumulative Percent 

≤ 50 feet <1 

≤ 100 feet 3 

≤ 500 feet 7 

Distance of Nearest Day Care Cumulative Percent 

≤ 100 feet 2 

≤ 500 feet 5 

Distance of Nearest Hospital Cumulative Percent 

≤ 100 feet <0.5 

≤ 500 feet 3 

Distance of Nearest Senior Community Cumulative Percent 

≤ 100 feet <1 

≤ 500 feet 3 

 1. Values are rounded off to the nearest integer unless they are less than 1. 

7. Ventilation Type

Ventilation type is used to identify emission release parameters that are needed 

for air dispersion modeling. On the Facility Survey, we assessed facility ventilation type 

by asking whether the facility has open doors, open windows, window fans, powered 

ceiling fans, non-powered ceiling fans, a local ventilation system (fume/exhaust hood or 

shroud over machine), a partial vapor barrier room, or a vapor barrier room. Based on 

information from the local air districts and information gained through site visits, we 

categorized the ventilation information obtained into all six ventilation types. These six 

ventilation types are: natural ventilation, wall fan, general ventilation, local ventilation 

system (LOC), partial vapor barrier room (PBR), and vapor barrier room (VBR). 

Natural ventilation is the category for facilities that do not have any type of 

ventilation beyond open doors, open windows, non-powered ceiling fans, and/or passive 

roof vents. Wall fan (or window fan) is the category for facilities that have, in addition to 
IV-11 

natural ventilation, a high capacity wall fan. General ventilation stands for facilities that 

have one or more high capacity powered ceiling fans but no additional ventilation 

enhancement over/around the machine. LOC is for the facilities that have a 

fume/exhaust hood or a shroud over the dry cleaning machine. PBR is for the facilities 

that have enclosed part of the machine to capture fugitive emission. And, VBR is for the 

facilities that have a room enclosure for their dry cleaning machine(s). A summary of 

the ventilation information results from the Facility Survey is listed on Table IV-8. 

Table IV-8. Ventilation Information 

Type of Ventilation Percent1

Natural Ventilation 8 

Wall Fan 8 

General Ventilation 48 

Local Ventilation System (LOC) 27 

Partial Vapor Barrier Room (PBR) 4 

Vapor Barrier Room (VBR) 5 

 1. Values are rounded off to the nearest integer unless they are less than 1 and may not add up to 100.

As shown on Table IV-8, about half of the facilities have general ventilation and 

general ventilation is the most common ventilation type in the industry. This information 

was compared with site-visit results. The Facility Survey result for local ventilation 

systems is about 27 percent; this is significantly higher than site visit results. In 

addition, the eight percent obtained for those that have natural ventilation is lower than 

site visit results. Further verification indicated that many owner/operators 

misunderstood the terminology used for types of ventilation in the Facility Survey. The 

ventilation information was modified based on the verification and is detailed discussion 

in Section B. 

8. Maintenance Information

Maintenance practices were obtained from the Facility Survey. Facility operators 

were asked how often they inspect the machine(s), what type of leak detector is used 

during inspection, how many certified operator(s) are on-site, and how often they 

regenerate the carbon in the secondary control machines. Because the Airborne Toxic 

Control Measure for Emissions of Perchloroethylene from Dry Cleaning Operations (the 

Dry Cleaning ATCM) contains statewide requirements for inspection and certified 

operator(s) for facilities that use Perc, the results indicate how well the industry is 

complying with the Dry Cleaning ATCM. 

The Facility Survey showed that the majority of the Perc facility operators inspect 

their machine on a weekly or daily basis. About five percent of the facilities responded 

inspecting their machine less frequently (note: the Dry Cleaning ATCM requires leak 

checks on at least a weekly basis). Based on the Facility Survey, leak checks are 

performed using a halogen leak detector (TIF detector) by a majority of the facilities. 

The TIF detectors that are used in the industry can start detecting Perc at around 
IV-12 

8 parts per million (ARB, 2004c). See Section G for more detailed discussion on Perc 

detectors. 

About 16 percent of the facilities have more than one certified operator with 

about 84 percent having only one certified operator. Although the alternative dry 

cleaning facilities are not required by the Dry Cleaning ATCM to have a certified 

operator on site, all responded that they have at least one certified operator on-site. 

The reason may be that many of the alternative dry cleaning facilities formerly used 

Perc. 

The Facility Survey also showed that about 65 percent of the facilities that have a 

secondary control machine would regenerate carbon according to machine 

manufacturer’s specification, while about 30 percent responded that the carbon is 

regenerated automatically. There is about three percent that reported not regenerating 

the carbon at all. If the carbon in the secondary control system is not properly 

regenerated, it might become over saturated and would not be efficient in adsorbing 

Perc. The summary of the maintenance information is tabulated on Table IV-9 below. 

Table IV-9. Summary of Maintenance Information 

All Users Perc Users Only

Frequency of inspecting machine Percent1 Percent1

Daily 44 42 

Weekly 50 53 

Monthly 3 3 

Bi-monthly <1 <1 

Quarterly <1 <1 

Twice a year <0.5 <0.5 

Yearly <0.5 <0.5 

Never <0.1 02

Number of certified operators on-site Percent1 Percent1

One 84 84 

Two 14 14 

More than 2 2 2 

Frequency of regenerating carbon Percent1 Percent1

According to machine manufacturer's 

specification 

N/A 65 

Machine regenerates carbon automatically N/A 30 

Never N/A 3 

Other N/A 2 

1. Values are rounded off to the nearest integer unless they are less than 1 and may not add up to 100. 

2. None reported.

 

9. Future Machine Purchase

The facility operators were asked whether they would buy a new or used 

machine if they had to replace their current machine or purchase a new machine. They 

were further asked what type of solvent that machine would use. As shown in 
IV-13 

Table IV-10, most facility owners would opt to purchase a new machine instead of a 

used one. Staff also observed this trend during site visits, where only a few mentioned 

that they might purchase a used machine due to price difference. Many commented 

that they do not intend to replace their machine in the near future. And even though 

less than 50 percent said they would use Perc in their new machine, it is still the solvent 

of choice compared to the alternatives. The second solvent of choice is DF-2000. 

Table IV-10. Summary of Future Machine Purchase 

Type of Machine Percent1

New 96 

Used 4 

Type of Solvent Percent1,2

Perc 44 

DF-2000 24 

Rynex 3 2 

Stoddard 3 

GreenEarth 15 

Liquid CO2 10 

EcoSolv 1 

PureDry 4 

Water (wet cleaning) 13 

Other 8 

 1. Values are rounded off to the nearest integer. 

 2. Values added to over 100 because of multiple entries per facility. 

Other information obtained from the Facility Survey is discussed in Section H. 

This information includes the amount of Perc purchased, the amount of clothes dry 

cleaned, and the amount and type of waste generated. 

B. Site Visit Results 

 At the beginning of the evaluation process, staff visited facilities around 

Sacramento to get feedback on the Facility Survey. After the Facility Survey was 

mailed in September 2003, staff visited over 100 facilities around the State to get more 

detailed data. The facilities were located in 66 cities and covered nine air districts. The 

local air districts visited include: Bay Area AQMD, Butte County AQMD, San Diego 

County APCD, Sacramento Metro AQMD, San Joaquin Valley Unified APCD, Shasta 

County AQMD, South Coast AQMD, Ventura County APCD, and Yolo/Solano AQMD. 

In addition, staff requested facility data from Monterey Bay Unified APCD and Santa 

Barbara County APCD. In all, 11 local air districts, encompassing about 97 percent of 

the facilities statewide, are represented in the site visit analysis. 

Most of the facilities were selected randomly. Some facilities were selected 

because they gave us the opportunity to learn more about ventilation practices and 

alternative technologies. During the site visits, staff measured receptor distances, 

gathered information regarding ventilation types, and gathered general information from 
IV-14 

the machine operator, owner, and/or worker. A copy of the Site Visit Survey is shown in 

Appendix B. A map of the facilities visited is shown in Figure IV-6 on page IV-15. 

The site visit facility information was compared with the Facility Survey results. 

The comparison of the amount of co-located facilities and the facility area and height is 

shown in Table IV-11. 

Table IV-11. Comparison of Amount of Co-location and Facility Size 

Facility Survey 

Results 

Site Visit Info 

Information on Co-location 

People live in bldg (above and next), 

(percent)1

2 4 

Facility size 

Average area (sq ft)2 1,900 1,900 

Average height (ft)1 14 13 

1. Values are rounded off to the nearest integer. 

2. Values are rounded off to the nearest hundred. 

 As shown on Table IV-11, the Facility Survey results compare well with the site 

visit information. The reason for the higher value of site visit co-location facilities may 

be due to the effort made to visit facilities with vapor barrier rooms and that the Bay 

Area AQMD requires vapor barrier rooms for certain co-located facilities. A comparison 

of distance to receptors is shown on Table IV-12. 

Table IV-12. Comparison of Distance to Receptors1

Facility Survey 

Results 

Site Visit Info 

Distance to Nearest business Cumulative Percent Cumulative Percent 

20 ft or less 56 55 

50 ft or less 70 93 

100 ft or less 77 98 

500 ft or less 83 98 

Distance to Nearest residence Cumulative Percent Cumulative Percent 

20 ft or less 4 9 

50 ft or less 15 16 

100 ft or less 28 36 

500 ft or less 63 79 

Distance to Other Receptors2 Cumulative Percent Cumulative Percent 

50 ft or less 3 1 

200 ft or less 10 10 

500 ft or less 19 21 

 1. Values are rounded off to the nearest integer. 

 2. Other receptors include: schools, day care, park, senior community, and hospital. 
Vista

Dixon

Chico

Novato

Fresno

Folsom

Clovis

Redding

Manteca

Hayward

Concord

Belmont

Stockton

San Jose

Hercules

Vacaville

Sunnyvale

San Mateo

San Diego

Fair Oaks

Encinitas

Elk Grove

Sebastopol

San Carlos

Sacramento

Chowchilla

Solana Beach

San Francisco

Santa Rosa

Figure IV-6. Map of Facility Site Visit Locations

IV-15



Arleta

Upland Reseda

Pomona

Orange

Downey

Carson

Sunland

Stanton

Fontana

Cypress

Burbank

Valencia

Torrance

Pasadena

Inglewood

Wilmington

Northridge

Costa Mesa

Buena Park

Simi Valley

Santa Paula

Lake Forest

Diamond Bar

Santa Monica

San Fernando

Thousand Oaks

Newport Beach

Montclair San Bernardino

La Crescenta

Granada Hills

Pico Rivera

Los Angeles, City of

Manhattan Beach

Hermosa Beach

Los Angeles Basin Sites
IV-16 

As shown on Table IV-12, there is reasonably good agreement between the 

Facility Survey and the site visit results on receptor distances. Table IV-13 shows a 

comparison of Facility Survey and site visit results on facility ventilation type. 

Table IV-13. Comparison of Facility Ventilation1

Facility Survey 

Results 

Site Visit Info Bay Area 

AQMD 

Type of Facility Ventilation Percent Percent Percent 

Natural ventilation 8 22 16 

Wall Fan 8 9 8 

General ventilation 48 60 55 

Local Ventilation System (LOC) 27 1 6 

Partial Vapor Barrier Room (PVR) 4 1 8 

Vapor Barrier Room (VBR) 5 8 8 

 1. Values are rounded off to the nearest integer unless they are less than 1 and may not add up to 100. 

As shown on Table IV-13, there are significant differences between the 

Facility Survey and site visit results on some of the facility ventilation data, with the LOC 

values having the greatest contrast. Because of the difference between these results, 

staff compared them to those of the Bay Area AQMD (also shown on Table IV-13). The 

Bay Area AQMD is the only local air district that requires enhanced ventilation when the 

potential cancer risk exceeds a certain level, historically 100 in a million. About 200 dry 

cleaning facilities in that district had installed some form of ventilation to achieve the 

100 in a million risk level. In addition, Bay Area AQMD required all facilities co-located 

with residences to install a vapor barrier room, and recent amendment to the Bay Area 

AQMD’s Toxics New Source Review policy require all new facilities to have a total risk 

of less than 10 in a million. Existing facilities that replace their Perc machine(s) will be 

treated as new sources. 

As shown on Table IV-13, the Bay Area AQMD values agree better with the site 

visit results. To better understand this difference, staff conducted site visits to four 

Sacramento facilities that reported having LOC on the Facility Survey. During the site 

visits, all four owner/operators explained that they did not understand fully what was 

meant by LOC and checked it by mistake. Therefore, staff concluded that many of the 

dry cleaning owner/operators must have a different interpretation of the terms used. 

Unfortunately, this potential for misinterpretation did not arise during our field testing of 

the Facility Survey. Because the LOC impacts the percentages on the other categories 

of facility ventilation, our assessment of facility ventilation type is based on site visit and 

Bay Area AQMD information. 

C. Machine Manufacturers Survey Results 

A Machine Manufacturers Survey was developed to assess list price of the dry 

cleaning machines. Other information requested included: recommended maintenance 

schedule, maintenance cost, and machine brochures. The Machine Manufacturers 

Survey (shown in Appendix C) provided staff with current information on machine and 
IV-17 

maintenance costs, recommended maintenance schedule/practices, and latest 

technologies available on the machines. 

When compared to the cost of a secondary Perc machine, the cost of the 

commercially available water-based cleaning system is either similar or less. In 

contrast, all other closed-loop machines used for the alternative solvents are generally 

higher in cost. The most costly machine type is the one used for liquid CO2. Detailed 

cost information/discussion is presented in Chapter VII. 

General maintenance practices for the closed-loop machines using Perc and 

other alternative solvents (except water) include: cleaning of button and lint traps, 

cleaning of the still, draining and cleaning of the separator, and cleaning and/or 

changing of filters. Other maintenance practices may include proper lubrication of 

machine parts, checking the pressure level, and changing the carbon for certain carbon 

filters and for secondary control machines. Therefore, the time and effort spent on 

maintenance procedures are similar. For special cases where a still is not needed for 

some alternative solvents, there might be some decrease in maintenance time. Also, 

although the maintenance practices are similar, the frequency recommended for 

maintenance varies with the manufacturer. 

Several features of the current technology on Perc machines minimize fugitive 

Perc emissions. These include the use of spin disk filters, automatic cleaning of the 

still, and secondary control devices. Spin disk filters, when compared to cartridge filters, 

do not need to be replaced regularly and therefore significantly reduce fugitive 

emissions associated with filter replacement. Spin disk filters also allow for the recovery 

of the Perc that is normally embedded in the used cartridge filters. Automatic cleaning 

of the still eliminates the need to open it, which can expose the operator to Perc fumes 

and increase fugitive emissions. Secondary control devices reduce the Perc content 

within the machine drum to below 300 parts per million (ppm) before the clothes are 

removed and therefore reduce fugitive emissions. 

D. Dry Cleaning Solvent Manufacturers Survey 

To ensure that our health and environmental impact assessment are based on 

the correct chemical(s), a Dry Cleaning Solvent Manufacturers Survey was sent to 

some of the alternative dry cleaning solvent manufacturers. This survey was primarily a 

request for solvent formulation and therefore we did not send out surveys to those 

solvent manufacturers where we already had information on solvent formulation. After 

the survey, staff obtained adequate formulation information associated with petroleum 

solvent cleaning (DF-2000TM Fluid, PureDry

, EcoSolv, Shell Sol 140 HT, Stoddard), 

volatile methyl siloxane cleaning (GreenEarth

), glycol ether cleaning (RynexTM), CO2

cleaning, and water-based cleaning systems. Several manufacturers also provided 

health and environmental impact data. Information gathered is used in our 

health/environmental impact evaluation. 
IV-18 

E. Perc Solvent Distributors Survey Results 

A Perc Solvent Distributors Survey (Distributors Survey) was developed to 

assess the amount of Perc that is sold to the California dry cleaning industry. 

Information for years 2001, 2002, and 2003 were gathered from the distributors. 

A summary of the total amount of Perc bought and sold by the distributors for those 

three years are shown in Table IV-14. Based on Table IV-14, the majority of the Perc 

that was purchased was sold to the dry cleaning industry. In general, there is a 

continuing decrease in usage. This is most likely due to regulations that are in place 

and improved processes. 

For comparison purposes, the amount of Perc purchased by the dry cleaning 

industry was calculated based on the Facility Survey. Since the estimated total number 

of machines around the state is about 5,500 (based on 5,040 facilities and 1.091 

machines per facility), and the percent of Perc machines about 85, the usage can be 

estimated from facility survey. The result is compared with the Distributors Survey in 

Table IV-14. As shown on Table IV-14, the Distributors Survey results compare well 

with the facility survey results and there is a gradual decrease in the amount of Perc 

sold to the dry cleaning industry. 

Table IV-14. Summary of Perc Usage1

Sold to Dry 

Cleaning 

Industry In 2000 

(Gallons) 

Sold to Dry 

Cleaning 

Industry In 2001 

(Gallons) 

Sold to Dry 

Cleaning 

Industry In 2002 

(Gallons) 

Sold to Dry 

Cleaning 

Industry In 

2003 

(Gallons) 

Distributors Survey N/A2

 378,000 346,000 320,000 

Facility Survey 393,000 381,000 365,000 N/A3

1. Values are rounded off to the nearest thousand.

2. Value was not obtained from the Distributor Survey. 

3. Value was not obtained from the Facility Survey.

The values obtained from the Distributors Survey are low when compared to an 

estimate by the Halogenated Solvents Industry Alliance, Inc. (HSIA). They estimated, 

based on population, that the volume sold to California dry cleaners is about 12 to 13 

percent of the national volume, which in 2002 would have been 5.5 to 6 million pounds 

or 410,000 to 440,000 gallons (ARB, 2004h). This suggests that the California dry 

cleaning industry uses less Perc than the national average. In addition, current 

information from the Perc producers of 323,000 gallons and 236,000 gallons sold to the 

California dry cleaning industry in 2003 and 2004, respectively, confirmed the 320,000 

gallons obtained from the Distributors Survey for 2003. (ARB, 2005e). 

F. Perc and DF-2000 Sludge Test Results 

To support emission analysis of the dry cleaning processes, liquid sludge from 

Perc machines and DF-2000 machines was tested for solvent content. The standard 
IV-19 

operating procedures for determining Perc and DF-2000 in sludge are shown in 

Appendix D and E, respectively. Eight Perc sludge samples and two DF-2000 sludge 

samples were obtained and tested. The test results compared well with the 50 percent 

Perc reported to the ARB by three waste haulers in 1991. The average results are 

similar to data provided by the South Coast AQMD. Detailed test results are shown in 

Appendix F. A summary of the test data compared with South Coast AQMD data is 

shown in Table IV-15. 

Table IV-15. Summary of Perc and DF-2000 Sludge Tests 

Machine Type Number of 

tests 

Wt% 

Solvent 

in 

Sludge1

Weighted

Average 

Wt% 

Solvent 

in 

Sludge1

Sludge 

Density 

(lb/gal)

Weighted 

Average 

Sludge 

Density 

(lb/gal) 

Perc Primary (ARB 2004-2005) 6 35% 9.69 

Perc Primary (South Coast)2 4 59% 45% 10.77 10.12 

Perc Secondary (ARB 2004-2005) 2 44% 9.88 

Perc Secondary (South Coast)3 20 46% 46% 9.92 9.92 

DF-2000 (ARB 2005) 2 20% 7.55 

DF-2000 (South Coast)2 10 46% 42% 7.71 7.68 

1. Values are rounded off to the nearest integer.

2. South Coast, 2002. 

3. Based on preliminary data from South Coast (3 quarters of data). 

 The test data shown on Table IV-15 include weight percent of solvent in sludge 

and sludge density. Also shown on Table IV-15 are calculated weighted average values 

of weight percent of solvent in sludge and sludge density. These weighted average 

values are used in emission calculations shown in Section H. Comparing the ARB and 

South Coast AQMD values for the weight percent of solvent in sludge shows the values 

obtained for the Perc secondary test series to differ by only two percent; however, for 

the Perc primary and the DF-2000 test series, the difference was 24 percent and 

26 percent respectively. For the Perc Primary test series, with sample sizes of six and 

four and the range of the two series overlapping, the difference between the averages 

do not indicate systemic differences. The same is true with the DF-2000 test series. In 

all three cases, the weighted average of the ARB and South Coast AQMD test series 

combines the two sets of data to provide more representative data. 

G. Leak Detector Evaluation 

Based on observations during site visits and conversations with ARB training 

staff and local air districts, Some Perc facility operators do not use their halogenated 

hydrocarbon detector (HHD) as often as they are required. The reason is that most of 

the HHDs do not give quantitative results. A majority of the Perc facilities use HHDs 

made by TIFTM Instruments, Inc. (TIF detectors) that would beep when Perc or other 

volatile organic compounds (VOCs) were detected. The threshold level for beeping to 

begin is around eight ppm (ARB, 2004c). The TIF detectors can not be easily used to 
IV-20 

accurately determine whether a facility is in violation because the Dry Cleaning ATCM 

requirement for the facility to fix the leak is at 50 ppm. 

Staff looked at what is available in the industry for Perc detection and conducted 

a limited evaluation. Ten portable detectors, in addition to a TIF detector and a 

photoionization detector (PID) that was available and served as reference, were 

evaluated. The range of technologies tested included: PID, gas sensitive 

semiconductor, colorimetric tube, infrared, and heated diode sensor technology. Cost 

information for the detectors is shown in Chapter VII. The evaluation included two 

phases. During the first phase, the detectors were evaluated under laboratory 

conditions to determine detection accuracy and response time to Perc standards. 

During the second phase, a TIF detector, the reference PID, and those detectors that 

had less than 30-second response time were selected and tested in dry cleaning 

facilities. The objective of this phase was to compare detector response time to Perc 

levels around the machines, to actual leaks, and were used to measure background 

Perc concentrations within the facilities. 

A memorandum (memo) from ARB’s Monitoring and Laboratory Division (MLD) 

detailing the laboratory evaluation effort for nine of the portable detectors is shown in 

Appendix H. Only one detector was not mentioned in the memo because it was tested 

after the memo was written. Based on laboratory evaluation results, staff tested nine 

detectors in dry cleaning facilities. Two of the nine detectors were modified Aeroqual 

detectors that included a built-in fan in the sensor head. In addition to the nine 

detectors, staff also tested the TIF detector and compared readings with a PID 

(manufactured by PE Photovac International Inc.) used by staff of the Sacramento 

Metropolitan AQMD. 

A summary of the results is shown on Table IV-16 on page IV-21. In all cases, 

the PID detectors with an internal pump performed well and provided quantitative 

results. The Aeroqual 200 Leak Detector (different from the Aeroqual 200 used for 

monitoring purposes) was also deemed suitable for leak checks and provided 

quantitative results within 10 percent uncertainty at a 50 ppm Perc level. With the 

exception of TIF-5100, the detectors that used diffusion for sample delivery had 

response times of 5 seconds or more in the field and were deemed not suitable for leak 

detection. The Tek-Mate and the TIF-5100 were sensitive to Perc and will indicate 

leaks at levels below 50 ppm. The facility background concentrations were mostly 

non-detectable with the limit of detection of the PID detectors at around 1 or 2 ppm; the 

largest background concentration reading was between 5 to 10 ppm. 
IV-21 

Table IV-16. Summary of Leak Detector Evaluation 

Model and 

(Manufacturer) 

Detection 

Principle 

Sample 

Delivery 

Display Response Time1

(sec) 

Leak Check 

Suitability2

Gas Alert Micro 5 

(BW 

Technologies) 

Photoionization Diffusion LCD with audio 

and visual alarms

5 – 10 No 

PhoCheck 1000 

(Ion Science) 

Photoionization Internal pump LCD <5 Yes 

MiniRAE 2000 

(Rae Systems) 

Photoionization Internal pump LCD with visual 

alarms 

<5 Yes 

Aeroqual 200 

Leak Detector 

(Aeroqual) 

Gas Sensitive 

Semiconductor 

Internal fan LCD with audible 

alarms 

<5 Yes 

Aeroqual 500 

(Aeroqual) 

Gas Sensitive 

Semiconductor 

Diffusion LCD with audio 

alarm 

20 – 30 No 

Aeroqual 500 

with build-in fan3 

(Aeroqual) 

Gas Sensitive 

Semiconductor 

Internal fan LCD with audio 

alarm 

5 – 10 No 

C-21 

(Eco Sensors,Inc.)

Gas Sensitive 

Semiconductor 

Diffusion LED bar with 

audible alarm 

No Response4 No 

D-Tek 

(Inficon) 

Infrared Internal pump Audible with LED 

bar 

No Response No 

Tek-Mate 

(Inficon) 

Heated Diode 

Sensor Technology

Internal pump Audible with low 

and high 

sensitivity options

<5 Yes 

TIF-5100 

(TIF Instruments) 

Heated Diode 

Sensor Technology

Diffusion Audible <5 Yes 

Draeger CMS 

(Draeger) 

Colorimetric Internal pump LCD 110 No 

HW 101 reference 

analyzer 

(h-nu Systems) 

Photoionization Internal pump Analog 

Potentiometer 

<5 No 

1. Response time is the approximate time needed for the detector to display a stable concentration. 

2. Leak check suitability based on response time of less than 5 seconds in the field. 

3. Laboratory testing done after the memorandum in Appendix H was written. 

4. No response to calibrated standards, may require humidified gas sample. 

H. Emissions from Dry Cleaning Operations 

Emissions from dry cleaning operations are calculated based on a material 

balance approach. The amount of solvent that is consumed by a dry cleaning operation 

is either emitted into the air or is embedded in the waste or in clothes that are removed 

from the facility. Equation 1 shows the material balance relationship. 

(1) Solve = Solvc - Solvw - Solvclothes

 where: 

 Solve = volume in gallons of solvent emitted to the atmosphere from 

 a dry cleaning facility, 

 Solvc = volume in gallons of solvent consumed in a dry cleaning facility, 
IV-22 

 Solvw = volume in gallons of solvent that exit a dry cleaning facility in 

the waste products, such as still bottom, separator water, 

and used cartridge filters, and 

 Solvclothes = volume in gallons of solvent that exit a dry cleaning facility in 

 clothes. 

 

Information from our workgroup and from our site visits showed that a three-year 

average of solvent purchased is a good indication of the amount of solvent used by a 

machine each year. The exception will be newly purchased machines because they 

initially use more solvent during the first year of operation due to the initial fill 

(ARB, 2004a). Therefore, the average volume of solvent used by a dry cleaning 

machine in California can be estimated from purchase amounts after excluding the 

newly purchased machines. For example, the three year average Perc purchased for a 

Perc primary machine is about 80 gallons per year, which happened to be the same as 

the amount consumed per year is estimated by calculating the three year average 

without newly purchased machines. 

The three-year average method works well with Perc facilities; however, it did not 

work well with DF-2000 facilities because approximately 60 percent of the machines are 

two years or newer. If the newly purchased DF-2000 machines for the three years for 

which we had solvent usage data were not used, we would be left with a small subset of 

data. Since the difference in solvent usage from newly purchased machines occur 

during the first year of machine operation, it is assumed that excluding machines that 

were purchased in 2002 and using average 2002 solvent purchases would be a good 

approximation of average solvent consumption for DF-2000 machines. The average 

DF-2000 consumption calculated is 89 gallons per year. This assumption was 

compared with Perc secondary machine data and the calculated amount of Perc 

purchased during 2002 without machines purchased in 2002 was 68 gallons, the same 

as the value calculated using a three year average excluding newly purchased 

machines. 

Table IV-17 on page IV-23 shows the amount of solvent consumed, three-year 

average of clothes dry cleaned, solvent consumed, still bottoms generated, and the 

number of filters used for facilities that used Perc primary machines, Perc secondary 

machines and DF-2000 machines. As shown on Table IV-17, there are three types of 

cartridge filters that are used in the machines. These are standard, split, and jumbo 

cartridge filters. A majority of the machines that use cartridge filters only use standard 

cartridges. Some of the machines have a combination of the three types of cartridge 

filters and they are designated as such on the table. In addition to cartridge filters, a 

portion of the machines have spin-disk filters. There are two types of spin-disk filters, 

powdered and non-powdered. As shown on Table IV-17, less than half of a percent of 

the Perc machines have both a powdered and a non-powered spin-disk. The machines 

that have cartridge filters may also have spin-disk filters; therefore, the sum of all the 

values on Table IV-17 under proportion of filters used is greater than 100. 

The volume of Perc that is in the still bottoms is calculated from the average 

amount of still bottoms produced (from Facility Survey data) and the weight percent of 
IV-23 

Perc in still bottoms. The weight percent of Perc that is in the still bottom was measured 

previously by ARB as well as by South Coast staff. The results compared well with a 

test series conduced by ARB staff in 2004-2005 (see Section F) and average values 

from the two test series are used for the calculation. For example, the annual average 

amount of still bottoms produced by a primary Perc machine is about 75 gallons. With 

an estimated average solvent weight percent for primary machines of 45 percent and an 

average density of 10.12 pounds (lbs) per gallon, the annual average amount of Perc in 

the sludge of a primary machine is about 25 gallons. 

The amount of Perc in separator water may be calculated from the volume of 

separator water produced by a facility and the Perc content in separator water. For 

example, the average volume of separator water produced by a primary machine is 

about 141 gallons (from Facility Survey, Table VI-17). The Perc content in separator 

water was measured during an ARB test program in 1997 and by an affiliate of ATC 

Associates Inc. (AVES). The average Perc content in separator water is about 150 ppm 

or 3.9 grams per gallon (gm/gallon) (AVES, 2000). Therefore, on average, about 1.2 lbs 

of Perc or less than 0.1 gallons of Perc is present in the separator water coming out of a 

primary machine in one year. 

Table IV-17. Facility Survey Summary for Emission Analysis 

Emission Analysis Information Perc Facilities 

Primary Machines Secondary Machines 

DF-2000 

Facilities 

Amount of clothes cleaned Pounds1 Pounds1 Pounds1

Average 44,000 52,000 53,000 

Yearly solvent usage and waste produced Gallons2,3 Gallons2,3 Gallons2,4

Solvent consumed 80 68 89 

Average Still Bottom Removed 75 88 90 

Average Separator Water Produced 141 191 210 

Amount of Filters Used Per Year Count2,3 Count2,3 Count2,4

Average number of Standard cartridge used 15 10 7 

Average number of Split cartridges used 13 7 11 

Average number of Jumbo cartridges used 7 5 9 

Proportion of Filters Used Percent3,5 Percent3,5 Percent4,5

Machine using Standard cartridge only 58 46 39 

Machine using Split cartridge only 7 11 4 

Machine using Jumbo cartridge only 5 10 6 

Machine using a combination of Standard, Split, 

and Jumbo cartridges 

4 8 9 

Machine using non-powdered spin-disk 31 55 42 

Machine using powdered spin-disk 13 11 27 

Combo (non-powdered and powdered) <0.5 <0.5 None 

1. Values are rounded off to the nearest thousand. 

2. Values are rounded off to the nearest integer, unless it is less than one. 

3. Values are averaged from three years of data, excluding newly purchased Perc machines. 

4. Value is obtained from 2002 data excluding data for machines purchased in 2002. 

5. Values are rounded off to the nearest integer unless they are less than one and may not add up to 100 because of combined 

usage of spin-disk and cartridge filters. 
IV-24 

The amount of Perc in clothes is estimated based on available test data. AVES 

conducted a study in 1997 which showed the average amount of Perc in clothes was 

about 99 milligram per kilogram of clothes (AVES, 2000). For example, the amount of 

Perc in 52,000 lbs of clothes is about 0.3 gallons of Perc. This is higher than the 

0.006 weight percent relative to the total Perc emitted from dry cleaning found in the 

Source Reduction Research Partnership in 1990 (ARB, 1993a). 

The amount of Perc in standard and split filters is estimated to be 0.5 gallons and 

the amount of Perc in a jumbo cartridge filter is estimated to be one gallon 

(ARB, 2004a). For example, for a facility that uses 13 standard filters a year, the 

amount of Perc that is disposed of in the filters is about seven gallons. 

A detailed look into machine types and amount of emissions shows that 

secondary machines are more efficient in Perc use compared to primary machines and 

converted machines. Because the number of converted machines is low (two percent 

of the total), it was not further divided into categories based on filter types. Within the 

categories of primary machines and secondary machines, the type(s) of filters used 

were identified and checked for difference in performance. There are three categories 

based on filter types: spin disk only, cartridge only, and combo. The category of spin 

disk only represent machines that operate with spin disk filtration and do not have any 

cartridge filters. The category of cartridge only represent machines that operate with 

cartridge filters only and do not have any spin disk filters. The combo category 

represents machines that have a combination of spin disk and cartridge filters. The 

percentage of each category is obtained from Facility Survey data and is shown on 

Table IV-18. 

The amount of sludge, separator water, and number of filters used for converted 

machines and for each of the categories of primary and secondary machines was 

obtained from the Facility Survey. The emissions are then calculated based on 

Equation 1 and are then normalized to the same amount of material dry-cleaned 

(46,600 pounds per year). A comparison of the normalized emissions for each of the 

categories is shown on Table IV-18 on page IV-25. 

As shown on Table IV-18, the results show that Perc emissions calculated for the 

converted machines are the highest, with primary machines having lower emissions, 

and the secondary machines emitting the least amount of Perc for the same amount of 

clothes cleaned. When comparing primary machines, there is a distinct difference in 

emissions between machines that use spin disk filters and a combination of spin disk 

and cartridge filters versus those that use cartridge filters only. Primary machines that 

operate with only cartridge filters emit about 41 percent more Perc when compared with 

those that have a spin disk filter. The difference in emissions between filter types for 

secondary machines is relatively small. Comparing average Perc secondary machine 

to DF-2000 machines, the weight percent of solvent emitted is very close, with 50 

percent and 49 percent, respectively. However, the actual amount in pounds per year 

emitted is higher for the Perc secondary machines when compared to DF-2000 

machines (410 pounds per year versus 230 pounds per year) because Perc is higher in 

density. 
IV-25 

Table IV-18. Emissions Comparison1

Machine Type Percent 

of 

Machine 

in 

Category

Solvent 

Usage 

(gal/yr)

Sludge

 Amt 

(gal/yr)

Amt 

Solvent 

in 

Sludge 

(Wt %) 

No. 

of 

Filter

Solvent 

Emitted 

(gal/yr)

Solvent

Emitted 

(Wt %) 

Solvent 

Ems 

(lb/yr) 

Converted 100 106 46 45 22 79 75 1073 

Primary (Spin Disk Only) 28 73 86 45 0 44 60 589 

Primary (Cartridge Only) 55 97 65 45 18 66 68 889 

Primary (Combo) 17 79 78 45 14 45 57 613 

Primary (Average) 100 86 74 45 10 56 65 759 

Secondary (Spin Disk Only) 32 65 90 46 0 28 48 383 

Secondary (Cartridge Only) 29 60 67 46 10 35 55 469

Secondary (Combo) 39 59 85 46 6 17 34 227 

Secondary (Average) 100 61 81 46 5 30 50 410 

DF-2000 100 78 79 42 4 36 46 230 

1. Values are normalized to 46,600 pounds of material cleaned per year and rounded off to the nearest integer.

 
V-1

V. POTENTIAL HEALTH IMPACTS 

A. Perchloroethylene 

Perchloroethylene (Perc) is the most common solvent currently being 

used in the dry cleaning industry. Exposure to Perc may result in both cancer 

and non-cancer effects. There are many human and animal studies which have 

been used to identify potential health impacts for exposure to Perc. Many of the 

human studies have been conducted among populations of dry cleaning workers. 

The Office of Environmental Health Hazard Assessment (OEHHA) staff has 

performed an extensive assessment of the adverse health effects of Perc, 

including available carcinogenicity data. Summary information on human and 

animal studies can be found in OEHHA’s Air Toxics Hot Spots Program Risk 

Assessment Guidelines, Part II, Technical Support Document for Describing 

Available Cancer Potency Factors, April 1999. 

The Air Resources Board (ARB) formally identified Perc as a toxic air 

contaminant in 1991. OEHHA concluded that Perc is a possible human 

carcinogen with no identifiable threshold below which no carcinogenic effects are 

likely to occur. Under Proposition 65, the Safe Drinking Water and Toxic 

Enforcement Act of 1986, the State of California listed Perc as a carcinogen in 

April 1988. In 1990, the United States Congress listed Perc as a hazardous air 

pollutant in subsection (b) of Section 112 of the federal Clean Air Act 

(42 U.S.C. 7412). The International Agency for Research on Cancer (IARC) has 

classified Perc in Group 2A, as a probable human carcinogen. The United 

States Environmental Protection Agency (U.S. EPA) is currently reevaluating 

Perc for carcinogenicity. 

In addition to cancer effects, there are short-term (acute) and long-term 

(chronic) non-cancer health effects associated with exposure to Perc. Acute 

toxic effects resulting from short term exposure to high levels of Perc may include 

headaches, dizziness, rapid heartbeat, and irritation or burns on the skin, eyes, 

or respiratory tract. Chronic exposure to lower Perc concentration levels may 

result in dizziness, diminished cognitive ability, and damage to the liver and 

kidney (ARB, 1993). Workers have shown signs of liver toxicity following chronic 

exposure to Perc, as well as kidney dysfunction and neurological effects. Effects 

on the liver, kidney, and central nervous systems from chronic inhalation 

exposure to Perc have been reported in animal studies (ARB, 1997). 

1. Pollutant-specific Health Values

 Dose-response or pollutant-specific health values are developed to 

characterize the relationship between a person’s exposure to a pollutant and the 

incidence or occurrence of an adverse health effect. A cancer potency 
V-2

factor (CPF) is used when estimating potential cancer risks and reference 

exposure levels (RELs) are used to assess potential non-cancer health impacts. 

Dose-response or pollutant-specific health values are developed to characterize 

the relationship between a person's exposure to a pollutant and the incidence or 

occurrence of an adverse health effect. 

The CPF, which is currently used for health risk assessment, describes 

the excess cancer risk associated with exposure to one milligram of a given 

chemical per kilogram of body weight. The inhalation unit risk factor (URF), 

which was used in the past for health risk assessment, is defined as the 

estimated upper-confidence limit (usually 95th percentile) probability of a person 

contracting cancer as a result of constant exposure to a concentration of 

1.0 microgram per cubic meter (μg/m3

) over a 70-year lifetime. The URF of 

5.9x10-6 (μg/m3)

-1 is converted to the cancer potency factor of 

2.1x10-2 (mg/kg - day)-1 by multiplying the URF by 3,500 and rounding to two 

significant figures. The factor of 3,500 is derived from a 70 kilogram (kg) human 

body weight, 20 m3 inhalation rate, and 1,000 factor unit conversion. 

An REL is a concentration at or below which adverse noncancer health 

effects are not likely to occur in the general population. RELs are designed to 

protect the most sensitive individuals in the population by including uncertainty 

factors in their development and are created for both acute and chronic 

exposures. An acute exposure is defined as one or a series of short-term 

exposures generally lasting less than 24 hours. A one-hour exposure is used to 

determine acute non-cancer impacts. Chronic exposure is defined as long-term 

exposure usually lasting from one year to a lifetime. 

As mentioned previously, exposure to Perc may result in both cancer and 

non-cancer effects. Table V-1 shows the health values for Perc that are currently 

adopted and approved for use in California. These health values have gone 

through a public comment and scientific peer review process. Of the currently 

used dry cleaning solvents, Perc is the only solvent for which there are adopted 

health values available for use in California. OEHHA has estimated interim RELs 

for several of the alternatives. Interim RELs are estimates based on approved 

OEHHA procedures; however, interim values have not gone through public 

comment and scientific peer review. 

Table. V-1. Adopted Health Values for Perc 

Health Effect Health Value 

Acute inhalation REL 2.0x104 μg/m3

Chronic inhalation REL 35 μg/m3

Inhalation unit risk factor 5.9x10-6 (μg/m3)

-1

Inhalation cancer potency factor 2.1x10-2 (mg/kg-d)-1
V-3

B. Perc Alternatives 

There is relatively little health data available on the alternatives and no 

California health values have been adopted. As a result, ARB staff requested 

OEHHA to review the health effects of alternative dry cleaning solvents as they 

are used in the dry cleaning industry. Appendix G is a copy of OEHHA’s 

December 2002 memorandum to ARB which provides both a summary of their 

literature review and toxicity data summaries for many of these compounds. 

Based on their literature review, OEHHA has estimated several interim RELs and 

is continuing to follow the peer-reviewed literature on toxicity studies for the 

alternative solvents. 

1. Hydrocarbon Solvent Cleaning (DF-2000, PureDry, EcoSolv, 

Shell 140, Stoddard)

Hydrocarbon solvents, sometimes referred to as mineral spirits and 

petroleum solvents, are mixtures of hydrocarbons with or without other materials. 

Hydrocarbons have been used in the dry cleaning industry for many years and 

are some of the more common alternatives to Perc dry cleaning. The 

hydrocarbon solvents are a unique mixture of carbon and hydrogen molecules 

that co-exist as linear and branched chains, as well as in cyclic forms 

(U.S. EPA,1998). 

For Stoddard solvent, the American Conference of Governmental 

Hygienists set a Threshold Limit Value (TLV) of 525 mg/m3

. The National 

Institute for Occupational Safety and Health (NIOSH) REL is 350 mg/m3

time-weighted average (TWA). Stoddard solvent can be irritating to the eyes, 

nose, throat, and can also have effects on the nervous system. 

(U.S. EPA, 1998) 

A recent two-year inhalation study of Stoddard solvent conducted by the 

National Toxicology Program (NTP) concluded that there was some evidence of 

carcinogenic activity in male rats (NTP, 2004). In general, this study confirmed 

previous studies on toxicity for Stoddard. Most of the studies found in the 

literature for short and long-term toxicity identified the kidney and liver as the 

major target organs (NTP, 2004). 

There is also very limited health information on other hydrocarbon 

mixtures. DF-2000

Fluid (DF-2000) contains C11 to C13 synthetic isoparaffin 

aliphatic hydrocarbons. PureDry

(PureDry) contains 95 percent mineral spirits, 

which can cause neurotoxicity, and eye and respiratory irritation at high 

concentrations (OEHHA, 2003). EcoSolv (EcoSolv) and Shell Sol 140 HT have 

similar hydrocarbon properties. 

Most information is lacking on the environmental persistence of these and 

other hydrocarbon mixtures, however the manufacturer of DF-2000 indicated that 
V-4

their solvent can exhibit moderate rates of biodegradation (ExxonMobil, 2003). 

The manufacturer of EcoSolv indicated their solvent can exhibit moderate to 

rapid rates of biodegradation (Chevron Phillips, 2005). 

For hydrocarbon mixtures, OEHHA has developed an interim chronic REL 

of 1,200 μg/m3. The development of this interim value, which has not been 

through scientific peer review, is based on a study by Phillips and Egan on male 

and female rats. Additional information on this study can be found in 

Appendix G. The scarcity of health information for hydrocarbon solvents is a 

concern. Although the limited data available indicates relatively low toxicity, 

there are no comprehensive studies which indicate that toxicity and 

carcinogenicity should not be a concern. More research in this area is needed 

before a better assessment of the health impacts from hydrocarbon emissions 

can be made. 

 An occupational exposure limit (OEL) can be calculated for various 

hydrocarbon solvents. Guidance values for individual hydrocarbon constituents 

or groups of constituents were recently published in an article A Proposed 

Methodology for Setting Occupational Exposure Limits for Hydrocarbon Solvents

in the Journal of Occupational and Environmental Hygiene, October 2005. 

(JOEH, 2005). Information on calculating OELs and guidance values for other 

substance groups can be found in the article. Note however, these guidance 

values have not been approved for use in California’s regulatory programs. 

2. Volatile Methyl Siloxane Cleaning

Decamethylcyclopentasiloxane, or D5, is a cyclosiloxane which is now 

being used as a dry cleaning solvent. Historically, it has been used as an 

ingredient in many personal health and beauty products. D5 is present in 

GreenEarth (GreenEarth) solvent. Dow-Corning, who manufacturers the 

solvent, conducted a two-year study with rats in which preliminary data showed 

an increase in tumors of the uterine endometrium. Preliminary findings may 

indicate that there is a potential carcinogenic hazard associated with D5

(U.S. EPA, 2003). The observance of adverse effects on the uterus by D5 is of 

concern (OEHHA, 2003). Because D5 is lipophilic there is also concern that D5

may bioaccumulate in the food chain. 

A study by Burns-Naas et al. (1998) evaluated the subchronic toxicity of 

D5. This study showed there were several minor changes observed in clinical 

biochemistry parameters; the most notable was an increase in gamma glutamyl 

transferase (a liver enzyme) in both sexes at the high dose. This study also 

showed that there was an increase in liver weight in rats. McKim et al. (1999) 

investigated the effects of D5 on the expression and activity of selected rat 

hepatic phase I and phase II enzymes. Additional information on the Burns-Naas 

et al. and McKim et al. studies can be found in Appendix G. 
V-5

In June 2005, D5 manufacturers submitted final toxicity testing data to 

ARB, OEHHA, Department of Health Services (DHS), and U.S. EPA. According 

to D5 manufacturers, this data supports their conclusion that D5 is safe when 

used as intended. After ARB, OEHHA, DHS and U.S. EPA review the data, a 

better assessment of the public health impacts from GreenEarth emissions can 

be made. 

3. RynexTM (Propylene Glycol Ether) 

RynexTM (Rynex 3) is a form of propylene glycol ether and water. This 

solvent had some changes in formulation since its inception. Rynex 3 represents 

the current formulation for Rynex 3. Currently, there is limited toxicity data on 

Rynex 3. 

Based on a recent study by NTP on a previous formulation for Rynex 3, 

propylene glycol t-butyl ether, OEHHA expressed concerns over its toxicity and 

carcinogenic potential. Of particular concern was the presence of tumors in 

mice. OEHHA has developed an interim chronic REL for propylene glycol t-butyl 

ether of 200 μg/m3 to prevent adverse effects in the respiratory system. In 

addition, an interim inhalation unit risk factor for cancer was estimated to be 

5.2x10-7 (μg/m3)

-1, about one-tenth that of Perc. There are no developmental or 

reproductive studies on the chemical. Appendix G has more detailed information 

on the toxicological studies for the previous formulation of Rynex 3, propylene 

glycol t-butyl ether. 

 The manufacturer of Rynex 3 has indicated that Rynex 3 is not 

carcinogenic and has low toxicity. A Rynex 3 fact sheet states that, based on 

laboratory animal studies, propylene glycol ethers do not cause the type of 

toxicological effects that are associated with exposure to ethylene glycol ethers 

(Rynex, 2005a). However, neither ARB nor OEHHA staff has verified this or has 

received these toxicological studies. 

 4. Carbon Dioxide Cleaning

As discussed in Chapter II, carbon dioxide (CO2) cleaning uses liquid CO2. 

The CO2 used in this process is an industrial by-product. There is no net 

increase in the amount of CO2 emitted; therefore, this process does not 

contribute to global warming. CO2 is naturally occurring and is routinely ingested 

in food products such as soft drinks. CO2 is also used in packaging for many 

foods such as salads, potato chips, and cookies. 

Design for the Environment (DfE), a cooperative project between the 

U.S. EPA and the garment and textile care industry, recognizes the CO2 cleaning 

process as one example of environmentally preferable technology that can 

effectively clean garments. The DfE conducted a case study on a Micell 

Technologies, Inc., CO2 system that uses CO2 in conjunction with a cleaning 
V-6

agent that enhances the cleaning ability of the liquid CO2. In the case study, 

Micell Technologies asserts that their cleaning system offers excellent cleaning 

performance across most garment components and a wide range of stains and 

soils. This system uses the same beverage-grade bulk CO2 that is distributed to 

more than 50,000 restaurants and other fountain beverage dispensers located in 

the United States. (U.S. EPA, 1999) 

 5. Professional Wet Cleaning

Most detergents used in Professional Wet Cleaning (wet cleaning) are a 

complex mixture of water and a variety of chemicals. Most formulations are trade 

secrets. Because there are a wide variety of formulations, there is difficulty with 

determining toxicity of these substances. Chemicals used in wet cleaning 

process commonly include spotting agents, detergents, fabric conditioners and 

sizing products. Other products may be used for cleaning leather and suede 

including water repellants. 

In general, detergents are approved for disposal into the sewer system by 

the sanitation districts. U.S. EPA examined the human health and environmental 

hazards of surfactants because they are the primary components of detergents. 

In general, they found that there was no expected health risk to the general 

public. (U.S. EPA, 1998). In addition, the draft report by Institute for Research 

and Technical Assistance, Evaluation of New and Emerging Technologies for 

Textile Cleaning, indicates that detergents are low in toxicity (IRTA, 2005). 

In U.S. EPA’s Cleaner Technologies Substitute Assessment: Professional 

Fabricare Processes (CTSA), U.S. EPA provided health hazard summaries on 

surfactants and surfactant aids for some example detergents. The following 

surfactants were included in their example detergents: cellulose gum (CG), 

cocamidopropyl betaine (CAPB), ethoxylated sorbitan monodecanoate 

(P-20), lauric acid diethanolamide (Lauramide DEA), sodium laureth sulfate 

(SLS), sodium lauryl isethionate (SLI). Surfactant aids include: acetic acid, citric 

acid, sodium citrate, and sodium carbonate. It is unknown how representative 

these example detergents were for detergents currently being used. Below is 

some health information on some of the surfactant and surfactant aids presented 

in the CTSA. 

 a. Surfactants

Several studies have been conducted on CG, a water-soluble cellulose 

ether. This and other water-soluble cellulose ethers exhibit very low oral toxicity, 

and no neurologic, reproductive, or mutagenic effects. (U.S. EPA, 1998) 

CAPB is reported as a potentially irritating substance. CAPB does not 

appear to have undergone any studies of reproductive or developmental toxicity 

or neurotoxicity or chronic studies of systemic effects. Results of one study, 
V-7

suggest that CAPB does not increase systemic tumors above background, but 

are not enough to be conclusive. (U.S. EPA, 1998) 

In both animals and humans, P-20 has been found to be essentially 

nontoxic following acute and long-term oral ingestion and to exhibit little or no 

potential for skin irritation and sensitization. (U.S. EPA, 1998) 

No human studies were located regarding the potential toxicity of 

lauramide DEA following oral or inhalation exposure. Lauramide DEA was not 

found to be mutagenic. The carcinogenic potential of lauramide DEA is currently 

being investigated. (U.S. EPA, 1998) 

SLS, following oral exposures, was found to be “moderately to slightly 

toxic” in acutely exposed animals and virtually non-toxic in chronically exposed 

animals. SDS does not appear to exhibit any reproductive, developmental, or 

carcinogenic effects in animals. (U.S. EPA, 1998) 

Limited information on SLI suggests that this chemical may not be a skin 

irritant and is not mutagenic. (U.S. EPA, 1998) 

b. Surfactant Aids 

At high concentrations, acetic acid can result in severe irritation in both 

humans and animals. Based on short-term mutagenicity tests, acetic acid does 

not interact with genetic material. Although no direct information on the 

carcinogenicity of acetic acid was located, one chronic study in rats found no 

evidence of tumors. (U.S. EPA, 1998) 

Citric acid is generally considered to be innocuous except in the case of 

ingestion of large quantities or chronic exposures. Citric acid has been shown to 

be a mild to moderate skin and eye irritant in humans following inhalation or 

dermal exposure. No information has been located discussing neurotoxic, 

mutagenic, or carcinogenic effects associated with citric acid exposures in 

animals or humans. Sodium citrate is expected to behave chemically like citric 

acid systemically, but may not have the irritant properties. (U.S. EPA, 1998) 

Sodium carbonate is a skin and eye irritant. Sodium carbonate is not 

developmentally toxic to mice, rats, or rabbits. No information was available 

discussing reproductive, neurotoxic, mutagenic, or carcinogenic toxicity from 

exposure to humans or animals. (U.S. EPA, 1998) 

 6. Green Jet

The detergent used in the Green Jet (Green Jet) system is called 

DWX-44. The Material Safety Data Sheet (MSDS) states that the product is 100 

percent biodegradable. It also states that it contains no petroleum solvents, 
V-8

volatile organic compounds, or products from the federal hazardous air pollutant 

list. ARB staff is not aware of any health studies on this detergent. 

7. 1-Propyl Bromide

Although currently not in use in California, 1-propyl bromide, also known 

as 1-bromopropane, is a solvent that is currently being considered as an 

alternative to dry cleaning. This compound is a neurotoxicant and reproductive 

toxicant (OEHHA, 2003) and was listed under Proposition 65 as a reproductive 

toxicant in December 2004. It causes sterility in both male and female test 

animals, and harms developing fetuses when tested in pregnant animals. It can 

damage nerves, causing weakness, pain, numbness, and paralysis 

(CDHS, 2003). Because this is a relatively new chemical, most health 

information comes from animal testing. 

OEHHA developed an interim chronic REL of 1,100 μg/m

3

 (220 parts per 

billion) for 1-propyl bromide from the reproductive toxicity data in the Ichihara 

(et.al.) study (OEHHA, 2003). Based on current toxicity data, OEHHA staff is 

concerned about its use as a dry cleaning solvent (OEHHA, 2003). 

C. Interim Health Values 

As mentioned earlier in this chapter, OEHHA has developed interim 

values for some of the dry cleaning alternatives. Interim RELs are estimates 

based on approved OEHHA procedures; however, interim values have not gone 

through public comment and scientific peer review. OEHHA is continuing to 

follow the peer-reviewed literature on toxicity studies for the alternative solvents. 

Table V-2 summarizes these values. Refer to Appendix G for a more detailed 

discussion on the applicability of these values to specific compounds. 

Table. V-2. Summary of Interim Health Values 

Compound Acute REL1 Chronic REL Cancer potency factor1

D5 (GreenEarth) N/A 700 μg/m3 N/A 

1-Propyl bromide N/A 1,100 μg/m3 N/A 

Hydrocarbon mixtures N/A 1,200 μg/m3 N/A 

Hydrofluoroether (HFE 7200) 

(a compound in PureDry) N/A 19,000 μg/m3

 N/A 

Perc2 2.0x104 μg/m3 35 μg/m3 2.1x10-2 (mg/kg-d)-1

1. N/A means not available - not enough health data is available to determine a health value for this compound. 

2. The values for Perc are approved by OEHHA and are included for comparison.
VI-1

VI. ENVIRONMENTAL IMPACTS 

Several potential environmental impacts have been identified that are associated 

with the use of dry cleaning alternatives and perchloroethylene (Perc). This chapter 

discusses the impacts on wastewater, groundwater contamination, hazardous waste 

disposal, soil, flammability, energy usage and air pollution. 

A. Wastewater 

Sanitation districts have been concerned about the amount of chlorinated 

compounds found in the waste effluent at treatment plants and the potential for illegal 

disposal of Perc dry cleaning wastes down the sewers. Many treatment plants do not 

have the equipment necessary to process industrial wastes such as chlorinated 

solvents that have been detected at elevated levels at some facilities. However, Perc 

dry cleaners are not expected to significantly add to this burden. The impact of influent 

concentrations of Perc from the dry cleaning industry appears to be low due to the 

changes in dry cleaning operations and the implementation of environmental regulations 

(NC, 2001). Based on information gathered from the Dry Cleaning Facility Survey 

(Facility Survey), dry cleaning facilities using Perc either use a wastewater treatment 

unit to recycle their Perc or they have their wastewater picked up by a registered 

hazardous waste transporter (in California, all hazardous waste must be managed 

offsite by a transporter that is registered with the California Department of Toxic 

Substances Control). It should be noted that spotting chemicals can also be a source of 

Perc. 

In general, it is prudent to check with the local publicly owned treatment works in 

the State before discharging any wastewater into the sewer. However, potential 

wastewater impacts of the alternative solvents were assessed based on available 

information. The carbon dioxide (CO2) cleaning process does not generate wastewater 

and would not have an impact. Dry cleaners that use other alternative solvents, 

including GreenEarth (GreenEarth), hydrocarbon, and glycol ether, can release the 

solvents to water, mainly in separator wastewater. Separator water was analyzed in a 

project conducted by the Institute for Research and Technical Assistance (IRTA) and 

the Los Angeles County Sanitation District (LACSD). Separator water from three 

facilities, each using one of the alternative solvents mentioned, was analyzed for certain 

metals, toxic organics and aquatic toxicity (IRTA, 2005). In all cases, the metal 

concentrations and the toxic organic concentrations were below detection limits. 

Additionally, in all three cases, the separator water did not exhibit aquatic toxicity 

(IRTA, 2005). 

 

In addition, IRTA and LACSD analyzed the wash and rinse effluents from four 

wet cleaning facilities for certain metals, toxic organics, and aquatic toxicity. None of 

the samples contained metal concentrations that exceeded hazardous waste levels. 

Perc and/or trichloroethylene (TCE) were found in the effluent from three of the wet 

cleaning facilities. In some cases, the concentrations of these toxics exceeded 
VI-2

hazardous waste levels. The origin of the TCE and at least some of the Perc is most 

likely spotting chemicals that are used to pre-spot garments. A few of the facilities had 

both wet cleaning and Perc machines and the Perc may have been entrained in 

garments cleaned in the wet cleaning machine. The analysis indicated that effluent 

samples from all four facilities did not exhibit aquatic toxicity despite the presence of 

Perc and/or TCE. (IRTA, 2005) 

B. Groundwater Contamination 

One of the concerns with the use of Perc is groundwater contamination. Perc is 

known to pass through porous surfaces, such as building walls, sewer lines, and 

cement floors (ARB, 1993). Therefore, Perc usage poses a significant threat to the 

safety of our groundwater. Perc has been detected in both wastewater and 

groundwater in the South Coast basin, with some levels in excess of the current 

drinking water standard of five parts per billion (South Coast, 2002). Perc has also 

been detected in 968 wells or approximately ten percent of the 9,500 wells tested in 

California as of March 1996, creating a need for an estimated three billion dollar state 

cleanup (CFCA, 2002). The implementation of environmental regulations and changes 

in the dry cleaning industry will help minimize the impact on groundwater contamination 

from Perc. 

Based on information available for the alternative solvents, groundwater 

contamination is not as large of an issue compared to Perc. When DF-2000TM Fluid 

(DF-2000) is released into the environment, volatilization from water to the air is 

calculated to occur in a few days. Non-volatized product in the natural environment will 

biodegrade at a moderate rate and not persist. (ExxonMobil, 2003) Other high flash 

point hydrocarbon solvents are expected to behave similarly.

The GreenEarth solvent is unlikely to leach into groundwater because it is not 

very soluble in water and readily sticks to soil particles (GreenEarth, 2003). Based on 

conclusive test data with other silicone materials, if spilled on the ground, 

Decamethylcyclopentasiloxane, or D5, is expected to decompose to carbon dioxide, 

silicon dioxide (sand), and water. According to a study conducted by the International 

Fabricare Institute (IFI), GreenEarth solvent has low solubility in water (<100 parts per 

billion (ppb)) and is very close in density to water; therefore, if it is discharged to water, 

it will initially form a surface film and then will rapidly evaporate into the air. The half-life 

for GreenEarth in surface water is estimated at between one to five days. Acute studies 

with trout, daphnia, and algae show no significant effects at the highest doses 

prescribed by the test methodology. If larger amounts of GreenEarth solvent are kept in 

contact with soil, it will also be expected to decompose to carbon dioxide, silicon dioxide 

(sand), and water. (IFI, 2002) 

 Groundwater contamination is not a concern using the CO2 process. At room 

temperature, CO2 can exist as a liquid if kept in a closed system at an elevated 

pressure. The cleaning systems used for CO2 are able to efficiently convert CO2 from a 

gas to a liquid. One of these systems permits 98 percent of the CO2 to be recycled 
VI-3

(U.S. EPA, 1999). In general, only a nominal amount of CO2 is then vented to the 

atmosphere. 

 Environmental fate on the RynexTM (Rynex 3) solvent is not readily available, but 

the Rynex 3 formulation is a type of propylene glycol ether. Proplylene glycol ethers are 

known to be biodegradable. All propylene glycol ethers are liquid at room temperature 

and all are water-soluble. Propylene glycol ethers are unlikely to persist in the 

environment. Two specific types of glycol ethers, proplylene methyl ether and 

propylene glycol methyl ether acetate, have shown rapid biodegradation in soil. 

(SIDS, 2003) 

C. Hazardous Waste 

Hazardous waste is regulated in California by a federally authorized State 

program. Under this program, Perc is classified as hazardous waste. In California, all 

hazardous waste at a facility must be transported off-site by a registered hazardous 

waste transporter. In general, it is the facility owner’s responsibility to determine 

whether the waste from the facility is hazardous. 

Waste generated by the use of Perc in dry cleaning includes the still bottoms 

from solvent distillation and the spent cartridge filters used to remove lint and insoluble 

soil from the extracted Perc. Cartridge filters are typically replaced every six months or 

less, depending on workload and manufacturer recommendation. Reusable spin disc 

filters are also used and the removed lint and dirt from the spin disc filters generate 

perc-contaminated waste. (JE, 2004) 

According to the Facility Survey the change in the amount of waste generated 

from hydrocarbon and GreenEarth technologies is relatively small compared to Perc. In 

terms of waste volume, the CO2 and Rynex 3 cleaning processes are expected to 

generate the least amount of waste compared to Perc and the other alternative 

technologies. In general, wastes from the mentioned alternative processes include 

spent filters and still bottoms. The still bottoms from four dry cleaning facilities that used 

hydrocarbon, GreenEarth, Rynex 3 and CO2, were analyzed in a study IRTA conducted 

with LACSD. The results of these tests showed excess levels of lead for one of the still 

bottom samples and three out of four of the still bottom samples exhibited aquatic 

toxicity (IRTA, 2005). Because none of the solvents contain lead and are not expected 

to exhibit aquatic toxicity, the results indicate that the spotting chemicals and detergents 

used may alter the characteristics of the waste streams. Alternately, waste streams 

from alternative processes can be handled as hazardous waste. Currently, registered 

hazardous waste transporters remove the wastes from hydrocarbon dry cleaning 

facilities as hazardous waste (ARB, 2004i). 

The water-based cleaning technologies also generate spent filters. Again, in the 

absence of contamination from hazardous compounds, handling as municipal solid 

waste is an option (JE, 2004). Additionally, the detergents that are used are 
VI-4

biodegradable and designed for discharge via the sanitary sewer. These detergents 

should be readily removed at the local treatment plant (JE, 2004). 

D. Soil 

Soil contamination has been a problem with Perc use. According to one report, 

Perc is found in more than 50 percent of the Superfund sites in the country 

(CFCA, 2002). However, there is always concern of soil contamination in all dry 

cleaning processes. Soil contamination can occur through accidental releases, such as 

spills, or during the distillation process from a boil-over. Although federal, state, and 

local environmental regulations have been developed to help minimize soil 

contamination, dry cleaners should take all necessary steps to contain spills and clean 

them up quickly. 

E. Flammability 

Flammable and combustible liquids are listed in different classes. The 

combustible liquids used in the dry cleaning industry are listed under classifications 

based on their flash point. Flash point is defined as the temperature at which a flame 

will ignite the solvent vapors. These combustible liquids are classified as Class II, 

Class IIIA, or Class IIIB. The use of these combustible liquids may require the issuance 

of fire permits. Class II liquids, like the Stoddard Solvent (Stoddard), have a flash point 

at or above 100 degrees Fahrenheit (°

F) and below 140°F. Class IIIA liquids have a 

flash point at or above 140°

F and below 200°F. The hydrocarbon solvents are an 

example of the Class IIIA liquids. Class IIIB liquids, like the Rynex 3 solvent, have a 

flash point at or above 200°F. Class IV liquids, such as Perc, are considered 

noncombustible and, therefore, are not potential fire hazards. (JE, 2004) 

Stoddard has been a popular dry cleaning solvent that saw a significant usage 

decrease based on fire hazard concerns. As mentioned above, this solvent is classified 

as a Class II liquid and has a flash point of 110°F. This hazard encouraged the 

petroleum industry to develop a new group of solvents that have a higher flash point. 

These new solvents are classified as Class IIIA and IIIB liquids and have a flash point 

above 140°

F. It is important to know that these hydrocarbon solvents are still 

considered hazardous materials by California Occupational Safety and Health Act 

(CAL/OSHA) standards because they are classified as combustible liquids. This group 

of solvents includes DF-2000TM Fluid (DF-2000), PureDry (PureDry), Shell Sol 140 HT 

(Shell 140), and EcoSolv (EcoSolv). DF-2000, with a flash point of 147°F, is currently 

the most popular hydrocarbon solvent being used. (South Coast, 2002) 

 There are a few other alternative solvents being used in the garment industry 

today. They are GreenEarth, Rynex 3, and CO2. The GreenEarth solvent is classified 

as a Class IIIA liquid and has a flash point of 170°

F. Like the hydrocarbon solvents, 

GreenEarth is considered a combustible liquid. Rynex 3, which has a flash point 

greater than 200°F, is classified as a Class IIIB liquid which is also considered a 

combustible liquid. (JE, 2004) Based on a study conducted by the North Carolina 
VI-5

Department of Environment and Natural Resources, CO2 is a weak solvent; therefore, a 

detergent mixture is used as a supplement to the base solvent. The detergent mixture 

contains hydrocarbon chemicals in order to dissolve certain soils. The hydrocarbon 

compound used in the detergent mixture has a flash point above 140°F and is classified 

as a Class IIIA liquid. While the CO2/detergent mixture is not expected to be a fire 

safety hazard, the detergent mixture by itself is a fire safety hazard. (NC, 2001) 

The water-based cleaning processes use detergents that are not considered a 

fire hazard. Therefore, there is no potential flammability risk involved with these 

processes. For comparison purposes, Table VI-1 below gives you a summary of the 

flash points and classifications of the commonly used solvents in the dry cleaning 

industry. 

Table VI-1. Summary of Flash Points and Classification 

for Commonly Used Solvents1

Solvent Flash Point Classification 

Perc N/A IV 

Stoddard 110°

F II 

DF-2000 147°

F IIIA 

PureDry2

350°

F IIIB/IIIA 

Shell 140 >143°

F IIIA 

EcoSolv >140°

F IIIA 

Rynex 3 >200°

F IIIB 

GreenEarth3

170°F IIIA 

CO2

4

 N/A N/A 

1. Source: Material Safety Data Sheet, unless otherwise noted. 

2. Dry cleaners and vendors have reported that the flash point can decline to the 140°F range during use because of the 

 perfluorocarbon that is in the Pure Dry mixture. If this is the case, it is classified as a IIIA solvent. 

3. Source: Cleaners Family, Volume 4. 

4. The detergent mixture used as a supplement with the CO2 solvent is a hydrocarbon and is classified as a IIIA solvent, 

but when used together with the CO2 it is not considered a fire hazard. 

F. Energy Usage 

According to a report prepared by Jacobs Engineering for the City of 

Los Angeles, the overall amount of electricity used by a shop running either a new Perc 

system or a solvent-based technology (hydrocarbon, GreenEarth, Rynex 3) is about 

1,100 Kilowatt-hour (kWh) per month. For water-based technologies, tests conducted 

by the Pollution Prevention Education and Research Center (PPERC) at a facility that 

switched from Perc to professional wet cleaning found a reduction in electricity use (to 

approximately 600 kWh per month). The CO2 system requires a 70 to 150-amp service 

to operate the refrigeration system necessary to maintain the CO2 in a liquid state. 

Peak load for the pumps and compressor could be up to 20 kWh. This is twice the peak 

load reported for the other alternative technologies and it could result in increased peak 

load demand charges. Therefore, the assumption is made that a CO2 shop will utilize 
VI-6

30 percent more power than a shop using Perc. Based on available information, 

Table VI-2 shows monthly energy usage for Perc dry cleaning and alternatives. 

(JE, 2004) 

Table VI-2. Estimated Monthly Electricity Usage1

Process Electricity Usage (kWh) 

Perc 1,100 

DF-2000 1,100 

GreenEarth 1,100 

Wet Cleaning 600 

CO2 1,430 

1. Source: JE, 2004.

 Chapter VII gives additional information on electricity usage for each machine 

used in each dry cleaning process. 

G. Air Pollution 

1. Impacts on VOC Emissions and Global Warming

 Tropospheric ozone (“bad” ozone) formation requires a mix of ozone-forming 

chemicals, also known as volatile organic compounds (VOCs), nitrogen oxides, oxygen, 

and sunlight. Any reduction in VOC emissions is expected to provide a beneficial 

environmental impact on air quality by reducing tropospheric ozone formation. The 

hydrocarbon solvents and the Rynex 3 solvent are classified as VOCs. An increase in 

the usage of these solvents may cause an environmental impact. For example, if the 

industry was to switch to the whole hydrocarbon dry cleaning process there would be a 

significant increase of about 1.7 tons per day of VOCs Statewide. 

 Greenhouse gases alter the amount of heat, or infrared radiation, that can 

escape the Earth’s surface and have been linked to a gradual warming of the Earth’s 

surface and lower atmosphere. While CO2 has been the traditional focus of greenhouse 

gas concerns, the CO2 used in the dry cleaning process is an industrial by-product from 

other industrial operations and does not contribute to global warming. In the United 

States, the largest source of greenhouse gas emissions is from fossil fuel combustion, 

which accounted for approximately 81 percent of greenhouse emissions in 1996. 

(JE, 2004) 

2. Workplace Exposure

 CAL/OSHA regulates the concentration of many toxic air contaminants and 

VOCs in the workplace environment. CAL/OSHA has established a permissible 

exposure limit (PEL) for several of these compounds (the PEL is the maximum, 

eight-hour, time-weighted average concentration for occupational exposure). Perc has 
VI-7

a PEL of 25 parts per million (ppm) and Stoddard has a PEL of 100 ppm. Although the 

remaining solvents do not have PELs, Table VI-3 gives a summary of any known acute 

and chronic health impacts. 

Table VI-3. Potential Health Impacts and 

Permissible Exposure Limit (PEL) 

Solvent Acute Chronic PEL 

Perc central nervous system; irritation to 

eyes, skin, and respiratory tract 

kidney, liver, and 

gastrointestinal system 

25 ppm 

Stoddard central nervous system; irritation to 

eyes, skin, nose, and throat1

Unknown 100 ppm 

DF-2000 central nervous system; irritation to 

eyes, skin, and respiratory tract2

unknown N/A 

PureDry central nervous system; irritation to 

eyes, skin, nose, throat, and 

respiratory tract2

unknown N/A 

EcoSolv central nervous system; irritation to 

eyes, skin, and respiratory tract2

unknown N/A 

Shell 140 central nervous system; irritation to 

skin, nose, throat, and respiratory 

tract2

unknown N/A 

GreenEarth (D5) mild eye irritation increase in liver weight3 N/A 

Rynex 3 headaches; irritation to eyes, nose, 

and throat1

unknown N/A 

CO2 irritation to skin and eyes,4 frostbite5 unknown N/A 

1. Source: U.S. EPA, 1998. 

2. Information taken from Material Safety Data Sheets. 

3. See Appendix G. 

4. Due to exposure to detergents used with the CO2 process. 

5. Due to exposure to liquid CO2. 
VII - 1

VII. COST ESTIMATION 

The data used in the cost analysis of the various dry cleaning processes was 

based on information collected from equipment manufacturers and distributors as well 

as from publicly available information. The categories covered in this analysis include 

estimates on the cost of machines, operation, installation, leak detectors, and control 

technology. 

A. Machine Cost 

Estimated machine costs are based on the Machine Manufacturers Survey and 

are presented in Table VII-1. As there are a variety of sizes and models that affect the 

actual price of each machine, costs are given in ranges for each technology. 

Table VII-1. Summary of Machine Cost from Survey1

Solvent Type Machine Type Rated Capacity 

(lbs) 

Cycle 

Time 

(minutes) 

List Price ($)2

Water (wet 

cleaning) Washer (soft mount) 15-42 12-35 8,800-30,400 

Water (wet 

cleaning) 

Washer (hard 

mount) 20-85 12-35 8,700-23,300 

Water (wet 

cleaning Dryer 15-135 12-30 2,100-12,900 

Water (Green Jet) Dry-to-Dry 45 32 30,000 

Perc Secondary Control 35-90 45-55 38,000-83,000 

Hydrocarbon Dry-to-Dry 30-90 45-60 36,000-98,000 

Stoddard Solvent Transfer 50-110 40 29,000-40,000 

Stoddard Solvent Dryer/Claimer 55-110 55 29,000-35,000 

GreenEarth3 Dry-to-Dry 35-90 45-60 43,000-98,000 

CO2

4

 Dry-to-Dry 60 35-40 140,000 

1. From Machine Manufacturers Survey, unless otherwise noted. 

2. This reflects manufacture list price, machines can cost less. Also, does not include installation costs. 

3. This does not include the annual GreenEarth “Affiliation Fee.” 

4. Source: ARB, 2005c. 

Professional wet cleaning (wet cleaning) systems consist of a separate washer 

and dryer and require tensioning equipment. The two most common tensioning 

equipment pieces used are the form finisher, with an average cost of $11,000, and the 

pants topper, with an average cost of approximately $9,900 (PPERC, 2004). When 

selecting a wet cleaning washer, a dry cleaner needs to choose between a hard mount 

washer and a soft mount washer. Hard mount washers are less expensive than soft 

mount washers, but require a custom concrete foundation and are not suitable for 
VII - 2

upper-floor or above-basement installations (PPERC, 2004). According to the Machine 

Manufacturers Survey a 35-pound soft mount washer is approximately $15,100 

whereas a 40-pound hard mount washer is about $14,200. The cost of a wet cleaning 

dryer with a 50-pound capacity is estimated at $4,500. Dry cleaners can expect to pay 

between $39,600 and $40,500 for a “typical” wet cleaning system (including tensioning 

equipment). Costs will be higher if a larger capacity washer or dryer is selected. 

The Green Jet (Green Jet) system uses one piece of equipment for cleaning 

and drying. According to the Machine Manufacturers Survey the cost of the machine is 

$30,000 for a 45-pound capacity. This process does not require tensioning equipment 

because it intermittently rotates the garments to minimize shrinkage (as well as 

wrinkles) at the end of the cleaning cycle. 

The GreenEarth (GreenEarth) dry cleaning machines with the capacity range of 

35-pounds to 90-pounds are list priced at $43,000 to $98,000 according to the Machine 

Manufacturers Survey. There is also an annual GreenEarth “Affiliation Fee” of $2,500 

per machine. If a facility has more than one machine, there is an annual “Affiliation Fee” 

of $1,250 for each additional machine. (ARB, 2005d) 

According to the Dry Cleaning Facility Survey (Facility Survey) results, a typical 

perchloroethylene (Perc) dry cleaning facility has an average machine capacity of 40 to 

45 pounds. If a Perc machine were to be replaced with an alternative dry cleaning 

machine, it would typically be replaced with a slightly larger machine. Table VII-2 gives 

a cost comparison of Perc secondary control machines and the alternatives, including 

hydrocarbon, GreenEarth, water-based cleaning, and carbon dioxide (CO2). 

Also shown on Table VII-2 are installation costs. The cost of installation varies 

according to the machine type. A Perc dry cleaning machine can be installed for $2,500 

to $3,000 unless the facility needs to have a chiller or water tower included in the 

installation. If this were the case, the installation cost would range from $3,000 to 

$5,000. The installation cost for a hydrocarbon machine and a GreenEarth machine is 

basically the same. The installation cost range for these two types of machines is 

$5,000 to $6,000. The current installation cost for a CO2 machine with a chiller is 

$50,000. As for wet cleaning, the installation cost for a complete wet cleaning process 

will range from $2,000 to 2,500. If a facility owner is replacing just one piece of 

equipment (e.g. the washer), the installation cost will be about $750 per piece. There is 

an increase in cost if the owner chooses to relocate the piece of equipment within the 

facility. If this were the case, this “relocation” cost would be $850 per piece. This 

increased cost is due to the installation of new lines and traps. (ARB, 2004a; 

ARB, 2004b; ARB, 2005c) 
VII - 3

Table VII-2. Machine Cost Comparison 

for a Typical Dry Cleaning Facility1

Machine Solvent Type Installation Cost Typical Machine 

Cost

Machine Cost Difference 

Perc (dry-to-dry) to 

Alternative (dry-to-dry)2

Perc-Secondary Control 

(40-lb capacity) 

Perc-Secondary Control 

(40-lb capacity) w/chiller or cooling 

tower 

$2,500 – $3,000 

$3,000 - $5,000 

$43,900 - 

Hydrocarbon (50-lb capacity) $5,000 - $6,000 $61,000 +$17,100 

GreenEarth (50-lb capacity)3 $5,000 - $6,000 $63,000 +$ 19,100 

Water-Based Cleaning 

 Green Jet (45-lb capacity) 

 Professional Wet Cleaning4

 (washer/dryer/tensioning equip.) 

 Soft Mount (25-35 lb capacity) 

 Hard Mount (30-40 lb capacity) 

$2,000 - $2,500 

$30,000 

$37,800-$40,500 

$35,700-$39,600 

-$13,900 

-$6,100 to -$3,400 

-$8,200 to -$4,300 

CO2 (60-lb capacity)5 $50,000 $140,000 +$96,100 

1. Based on information from ARB’s 2004 Machine Manufacturers survey, unless otherwise noted. 

2. The cost estimates given for the soft and hard mount wet cleaning system are for washer/dryer combination. 

3. This does not include the GreenEarth annual affiliation fee of $2,500 for the first machine purchased and the $1,250 for any additional 

machines purchased. 

4. Source: ARB, 2005. Also note that typically 30-pound capacity washer/dryer wet cleaning machines can usually replace a 60-pound 

capacity Perc dry cleaning machine (PPERC, 2004). 

5. Source: ARB, 2005c. 

B. Operating Cost 

There are various operating costs associated with the garment cleaning industry. 

The operating costs will vary according to the cleaning process. The most important 

operating cost variables include solvent cost, detergent and spotting agent cost, 

electricity cost, natural gas cost, waste disposal cost, filter cost, gasket cost and 

maintenance costs. Estimated natural gas cost was given only for those technologies 

for which ARB had therm usage information. The maintenance cost may include 

cleaning of traps and still, draining and cleaning the separator, cleaning and changing 

filters, lubricating machine parts, checking pressure level, and changing carbon filters. 

Solvent costs will vary according to the dry cleaning technology used. The 

hydrocarbon technology has a variety of alternative solvents available. The most 

commonly used alternative solvent is DF-2000TM Fluid (DF-2000). Table VII-3 gives an 

overview of the available solvents and what the current cost is to the industry. Perc 

solvent costs given on this table include the current $4 fee imposed by the 

October 2003 Assembly Bill (AB) 998, Air Quality: Nontoxic Dry Cleaning Incentive 

Program. In the wet cleaning process, water is used as the solvent; therefore, there can 

be a change in water usage when switching to wet cleaning. A study conducted by 

Pollution Prevention Education and Research Center (PPERC) showed that there could 
VII - 4

be a 17 percent increase in water usage after switching to wet cleaning. This amounted 

to a $4 per month increase for water usage. 

Table VII-3. Dry Cleaning Solvent Costs1

Solvent Cost 

Perc $19/gal. 

Hydrocarbon 

 DF-20002 $6.50-7.95/gal. 

 PureDry® $15/gal. 

 Shell Sol 140 HT (Shell 140) $5/gal. 

 EcoSolv® (EcoSolv)3 $6.50/gal. 

 Stoddard Solvent $3.63/gal. 

GreenEarth $17.50/gal. 

RynexTM (Rynex 3) $20/gal. 

CO2

4

 $0.12-0.25/lb 

Green Jet $12.80/gal. 

1. There is no solvent cost for Professional Wet Cleaning. The cost impact 

for this technology would be in an increase of water usage which is shown 

on Table VII-5. 

 2. Source: ARB, 2004d. 

 3. Source: ARB, 2004. 

 4. Source: Begley, 2004. 

 A comparison was made on total annual operating costs for a typical dry 

cleaning facility. These costs were derived using the assumption that a typical dry 

cleaning facility dry cleans an average of about 46,600 pounds of clothes each year, 

based on the Facility Survey. This estimate was used to normalize the annual operating 

costs of each process for a typical facility. 

According to the Facility Survey, it is estimated that a Perc dry cleaning facility 

uses about ten standard filters each year and the remaining alternatives, with the 

exception of CO2 and Green Jet, use about seven standard filters each year. Standard 

filters were used for the cost comparison because this is the size filter that is most 

commonly used by the industry. There is a minimal cost difference if the facility uses 

jumbo filters. Also, in some cases machines will require a spin disk filter which will incur 

an additional cost of $90 for each filter (PPERC, 2002). The CO2 systems typically will 

use two filters and a lint filter. The lint filter is typically changed out every two weeks. 

(Smerling, 2004) The Green Jet machine uses a filter bag, foam filters, and felts which 

can be cleaned and reused. Since this system is relatively new, the lifespan of the felts 

and filters is unknown and it is difficult to estimate annual replacement costs. However, 

if these components were to be replaced, the cost would be $100 for the filter bag, $20 

for the foam filters and $4 for the set of eight felts. 

Table VII-4 list the average therm and kilowatt hour (kWh) usage per dry cleaning 

machine for each process. Information gathered from the Machine Manufacturers 

Survey was used to calculate kWh for each machine. Therm usage was estimated 

based on numbers taken from a study conducted by PPERC. Cost estimates for gas 

usages were made using the July 2005 Pacific Gas and Electric (PG&E) rates of $1.21 

for summer months (April 1 through October 31) and $1.25 for winter months 
VII - 5

(November 1 through December 31). The 2005 Sacramento Municipal Utility District 

(SMUD) average rate of $0.10 per kWh was used to estimate electricity usage. 

Calculations used to estimate electrical cost can be found in Appendix J. 

Table VII-4. Average Machine Gas and Electricity Usage 

 for Each Dry Cleaning Process 

Machine Type Therm Usage/Month1 kWh Usage/Typical 

Load 

Perc 531 6.2 

Hydrocarbon 

 DF-2000 243 6.2 

 PureDry 243 6.2 

 Shell 140 243 6.2 

 EcoSolv 243 6.2 

 Stoddard Solvent unknown 4.1 transfer machine 

5.1 dryer/claimer 

GreenEarth 297 6.2 

Rynex 3 unknown 6.2 

CO2 156 9.3 - 9.7 

Green Jet2

 Option A (208 volts) 

 Option B (240 volts) 

unknown 

unknown 

5.8 

6.7 

Professional Wet Cleaning 388 3.2 washer 

5.8 dryer 

1. Source: PPERC, 2002 and PG&E, 2005 

2. The Green Jet machine is equipped with the option to run on 208 volts or 240 volts. 

Facilities also incur a cost for gasket replacement. When leaks are detected, 

repairs consist of replacing gaskets. If a facility owner hires a maintenance person to 

replace the gaskets they would be charged about $70 per hour for labor costs. The 

replacement cost for a set of gaskets is estimated at $274. For comparison purposes, 

the assumption is made that all gaskets would get replaced annually with a three hour 

charge for labor. 

Not all processes incur a hazardous waste disposal cost. For those processes 

that produce hazardous waste there will be an additional operating cost for disposal. 

Waste disposal costs for each of the technologies were calculated based on the amount 

of still bottom and separator water produced. The amount of still bottom and separator 

water produced were obtained from either the Facility Survey or the study conducted by 

the Institute for Research and Technical Assistance (IRTA). A complete comparison of 

all operating costs can be found on Table VII-5. The machine cost values in Table VII-5 

are based on a five year loan with a ten percent interest rate. Therefore, the values for 

the total annual costs on the table reflect the cost of the first five years of operation. For 

years six through the life of the machine, the total annual cost would not include a 

machine cost. The numbers in Table VII-5 are rounded to the nearest dollar value. 

 
VII - 6

Table VII-5. Annual Cost Comparison for the First Five Years 

of a Typical Size Dry Cleaning Facility1

1. Where applicable, costs are normalized to about 46,600 pounds of clothes dry cleaned per year for a typical facility. Additionally, costs are rounded to the n2. Therm usage is taken from PPERC, 2004a report using current PG&E gas rates. The gas usage for Stoddard and Rynex 3 machines are assumed to be the 3. Information is taken from ARB’s Machine Manufacturers Survey, unless otherwise noted. 4. Cost for standard filters is used for this comparison. Standard filters cost $32 each. Annual costs may vary slightly if the machine uses jumbo filters and spi5. Out of pocket costs assuming a five year loan and a ten percent interest rate. 6. Waste disposal costs range from $6.75 to $10 per gallon (ARB, 2005b). The average of $7 was used for this table. 7. Costs given are with the assumption that the facility has no waste water treatment unit. 8. Includes the current $4 Assembly Bill 998 fee. 9. This includes electricity cost for transfer machine and dryer/claimer. 10. Source: ARB, 2005c. 11. Required only in some local districts. 12. Source: ARB, 2005g. 13. Filter cost for a CO2 machine are $26 each and lint filter cost are $9 each. 

14. The cost given is the yearly financial impact increase for water when switching from dry cleaning to Professional Wet Cleaning (PPERC, 2002). 

15. Source: PPERC, 2002. 

16. This cost includes $4 for the set of eight felts; $100 for the lint bag; and $20 for the foam filters. 

17. It is important to note that the total operating cost shown for the Green Jet technology will increase because gas costs are unknown. 

Technology Solvent Average Cost 

Detergent/Spotting 

Agents 

Electricity 

Cost 

Gas Cost2 Average 

Maintenance3

Affiliation 

Fee 

Filters4 Cost to 

Replace Gaskets 

Machin

Cost5

Perc $1,1598 $1,500 $850 $7,800 $375 N/A $320 $500 $12,372 Hydrocarbon:  DF-2000 $546 $1,500 $850 $3,580 $250 N/A $371 $500 $17,674  PureDry $1,170 $1,500 $850 $3,580 $250 N/A $371 $500 $17,674  Shell 140 $390 $1,500 $850 $3,580 $250 N/A $371 $500 $17,674  EcoSolv $507 $1,500 $850 $3,580 $250 N/A $371 $500 $17,674 Stoddard Solvent 

$283 $1,500 $1,1609 $3,580 $600 N/A $371 $500 $17,674 

GreenEarth $1,715 $1,10010 $850 $4,370 $850 $2,500 $371 $500 $18,202 Rynex 3 $1,000 $100 (spotting 

agents only) 

$850 $3,580 $625 N/A $371 $500 $17,674 

CO2 $552 $1,500 $940 $2,290 $2,250 N/A $23813 $500 $50,121 Professional Wet Cleaning 

$0-$4814 $2,35515

(detergent/ conditioner only) 

$660 (washer/ dryer) 

$5,700 $32015 N/A N/A $500 $11,343 

Green Jet $1,152 $1,500 $600 Unknown $400 N/A $12416 N/A $8,573 
VII - 7

C. Leak Detector Cost 

Most dry cleaners currently use a halogenated-hydrocarbon detector made by 

TIFTM Instruments, Inc. (TIF) to check for vapor leaks. The cost of these detectors range 

from $170 to $250 depending on the model. After conducting a comparison of available 

detectors on the market, we found that there are detectors that may be able to give a 

more accurate reading of Perc concentration. The more sophisticated portable analyzer 

is the photo ionization detector (PID) and it has a cost range of $1,305 to $2,995. The 

C-21, Aeroqual 200, and Aeroqual 500 Gas sensors are comparable to the detectors 

presently used by the dry cleaning operators, but use the gas sensitive semiconductor 

technology. The Aeroqual 200 and 500 monitors are equipped with a digital display 

window. In addition, there are the D-TEK and TEK-Mate detectors that are comparable 

in cost to the TIF detectors. These gas sensors range from $160 to $1,200. The 

Draeger detector is also available with a cost of $1,600, but requires the use of a 

measuring chip, which is an additional cost of $67. This measuring chip is good for ten 

leak checks before it needs replacement. Table VII-6 shows a price comparison of the 

various makes and models. 

 

Table VII-6. Comparison of Cost for Perc Concentration Detectors 

Product List Price 

TIFXL-1A1 $ 170 

TIF 8800 Combustible Gas Detector $ 210 

TIF 8800A Combustible Gas Detector $ 240 

TIFRX-1A1 $ 240 

TIF 5750A1 $ 240 

TIF 8850 Combustible Gas Detector $ 250 

C-21 Gas Sensor $ 300 

TEK-Mate $ 160 

D-TEK $ 350 

Aeroqual Monitor 200 Series $ 580 

Aeroqual Monitor 500 Series $1,200 

Micro5 PID $1,305 

Draeger $1,6002

ToxiRAE Plus PID $2,050 

MiniRAE 2000 PID $2,995 

PhoCheck 1000 PID $1,999 

1. The TIFXL-1A has replaced the TIF 5000, TIF 5050A and TIFXL-1. The TIFRX-1A 

sensor has replaced the TIF 5550A and TIFRX-1. The TIF 5750A sensor has replaced 

the TIF 5650A. 

2. There is an additional cost of $67 for the measuring chip needed after ten leak checks. 

D. Control Technology 

There are several control options for the dry cleaning industry. Both Perc and 

hydrocarbon machines can be purchased with a secondary control system. For 

comparison purposes the average cost of a 35-pound capacity primary control machine 

is $38,000 and the average cost of a 35-pound secondary control machine is $43,000. 
VII - 8

Secondary control can be added to an existing machine with primary control for about 

$6,000. However, these retrofits do not typically perform as well as machines with 

secondary control installed at the factory (ARB, 2004b). Spin disks are also used as 

secondary control and can also be added on to a machine. The 1998 and newer 

machines are equipped with convertible filters, which means that the housing can 

be changed from cartridge to spin disk. The cost for this would be under $1,000, but for 

machines older than 1998 it would most likely be more (ARB, 2004b). 

Some local air districts require dry cleaning facilities to install room enclosures 

with ventilation systems. In a July 2000 report prepared by ATC Associates, Inc. 

(AVES) for the ARB, costs associated with room enclosures were identified. There are 

three different types of enclosure/ventilation systems: vapor barrier rooms (VBRs), 

partial vapor barrier rooms (PVRs), and local ventilation systems (LOCs). The capital 

costs between the three different types vary according to the size of the machine and 

how the machine is constructed and installed. Some rooms may need to be custom 

built to fit in a corner of a room or as a stand-alone structure. Cost of construction will 

vary due to dry cleaner’s needs and local air district requirements. Construction may 

include walls or the installation of a blower, exhaust system, foil, or fan. AVES 

contacted several construction companies and found that VBR construction varies 

between $5,300 to $8,500. The construction of a PVR would cost about $4,800, and 

the LOC would be about $3,100 to $4,300. (AVES, 2000; BLS, 2004) 
VIII-1

VIII. EFFICACY EVALUATION 

 Efficacy, or the ability to effectively clean clothes, is an important factor to 

consider when considering dry cleaning alternatives. Properties to consider include: 

cleaning ability, evaporation rate, and ease of purification through distillation. The 

solvent should not cause fabric to unnecessarily fade, shrink, weaken, or bleed color, 

and should be compatible with detergents. 

The overall cleaning ability of a process depends on soil chemistry, textile fabric 

type, transport medium (aqueous vs. non-aqueous), chemistry of the additives 

(detergents, surfactants), the use of spotting agents, and process considerations (e.g., 

time, temperature, and mechanical actions) (U.S. EPA, 1998). Over 95 percent of all 

the soils are water soluble (Cleaners Family, 2004). The Kauri Butanol (KB) number is 

used to estimate the degreasing efficiency or cleaning ability of a solvent. High KB 

values generally indicate a strong cleaning ability, whereas a low KB value indicates a 

weaker cleaning ability. Higher KB values are usually more efficient in removing oil and 

grease stains, but a lower KB value may be safer on some dyes, adhesives, and trim 

fabrics. Therefore, a solvent with a high KB value may not be suitable for all 

applications. Table VIII-1 on page VIII-4 lists KB values and summarizes cleaning 

performance for perchloroethylene (Perc) and the alternatives. 

A. Hydrocarbon Solvent Cleaning 

Typically, solvents are more effective in cleaning oil stains, and 

water-based chemicals are more effective in cleaning sugar, salt, and perspiration 

stains. The cleaning process can be enhanced with the use of spotting agents, 

alternative detergents, surfactant additives, and other process modifications such as 

cleaning time, temperature, or mechanical action (U.S. EPA, 1998). With the use of 

specially formulated detergents it is believed that hydrocarbon solvents have a cleaning 

capability almost equal to Perc. 

Hydrocarbon solvents include: DF-2000TM Fluid (DF-2000), PureDry

(PureDry), 

Stoddard, EcoSolv (EcoSolv) and Shell SOL 140 HT (Shell 140). Many operators who 

have switched from Perc to hydrocarbon solvents have reported that fabrics come out 

fresher with no odor and that they could clean a wide range of items. Some operators 

have complained that clothes feel oily; however, that could be due to improper drying. 

Some users also report that the clothes felt softer, were easier to press, and have a 

better finish than clothes cleaned in Perc. (JE, 2004) 

PureDry is a blend of isoparaffinic hydrocarbon with a chemical additive produced 

by 3M. Efficacy testing for PureDry was done at Walt Disney World Textile Services. 

The clothes were cleaned to exceptional standards and without residual solvent odor in 

the finished garment (JE, 2004). 
VIII-2

B. RynexTM 

The Air Resources Board (ARB) staff was not able to locate any independent 

efficacy testing for RynexTM (Rynex 3). However, the manufacturer claims that Rynex 3 

is a superior, gentle cleaner (when compared to Perc) that can handle a wide variety of 

fabrics. The manufacturer has indicated that Rynex 3 has been field tested and has 

determined that it has outstanding cleaning properties and removes more stains during 

normal cycling so that less pre- and post-spotting is required. They also claim that it 

removes water soluble stains better than other solvents (Rynex, 2005). These claims, 

however, have not been verified with independent testing. 

C. Water-based Cleaning Systems 

Several tests have been conducted on water-based cleaning systems. In 1999, 

the Pollution Prevention Education and Research Center (PPERC) published a study on 

the performance evaluation of a facility converting from Perc dry cleaning to 

Professional Wet Cleaning (wet cleaning). The performance evaluation showed that 

over 99.5 percent of the garments that would have been dry cleaned were able to be 

wet cleaned. Claims for ruined garments were the same for both Perc dry cleaning and 

wet cleaning. Although the rate for additional work (redos) initially increased when the 

facility switched to wet cleaning, the rate dropped after a three-month transition period 

(PPERC, 1999). This may indicate that operator training has a considerable impact on 

the reported efficacy of this technology. 

In 2003, the PPERC published an assessment of the Green Jet

(Green Jet) 

System. The assessment consisted of interviews and site visits with facility owners 

using Green Jet. Several advantages and disadvantages were identified. The shop 

owner indicated that the advantages of the system were that Green Jet did not require 

as much experience or skill as the hydrocarbon equipment and that there was minimum 

wrinkling and shrinkage. Some of the disadvantages pointed out by the owner were 

that: 1) stain removal was difficult; 2) heavily soiled garments could not be processed; 

and, 3) additional technology was required for garments with a high level of oil or water 

based stains, or for heavily soiled items. Overall, the assessment indicated that 

although Green Jet does a good job removing surface soils, it may need to be 

supplemented by another cleaning system to handle the full range of textiles, 

particularly in situations where heavily-soiled garments need to be processed. 

(PPERC, 2003) 

D. Carbon Dioxide Cleaning 

Although ARB staff was not able to locate any independent efficacy testing on 

CO2 cleaning, one CO2 machine manufacturer performed testing that was published by 

the United States Environmental Protection Agency’s (U.S. EPA) Design for the 

Environment. Design for the Environment is a cooperative project between U.S. EPA 

and the garment and textile care industry garment and textile care partnership. One 

advantage, according to the manufacturer, is that the color retention can meet or 
VIII-3

exceed that of Perc dry cleaning. One exception to this is certain triacetate and acetate 

fabrics with specific yellow dispersive dyes. There was some shrinkage for garments 

that were triacetate-based only. However, these garments are quite rare. Triacetate 

based garments may be better handled by professional wet cleaning. (U.S. EPA, 1999) 

E. GreenEarth

The International Fabricare Institute (IFI) conducted testing on the efficacy of 

GreenEarth

 (GreenEarth) solvent under a contract to GreenEarth (IFI, 2002). This 

solvent contains decamethylcyclopentasiloxane (D5), which is the primary cleaning 

agent in GreenEarth. GreenEarth was ranked in several different categories 

including: cleaning performance, the ability to handle garments that dry cleaners 

currently process, affordability, capital costs, health issues, and contamination issues. 

Based on the testing, IFI concluded that stain removal was comparable to Perc, 

although not quite as effective in removing solvent soluble stains. For the purpose of 

the testing, solvent soluble stains included ball point ink, vegetable oil, and shoe polish. 

Overall, IFI found that GreenEarth cleaning is a viable alternative to Perc. 

Table VIII-1 on the following page lists KB values and summarizes cleaning 

performance for Perc and the alternatives. 
VIII-4

Table. VIII-1. Summary of KB Values 

and Cleaning Performance of Dry Cleaning Solvents 

Solvent KB Value Cleaning Performance 

Perc 92 Oil-based stains, most 

water-based stains, silks, wools, 

rayons. Not good for delicates. 

Stoddard 32-39 Less aggressive than Perc for oilbased stains. Can handle 

delicate garments. 

PureDry 37-40 Less aggressive than Perc for oilbased stains. Can handle 

delicate garments. 

Shell 140 N/A Less aggressive than Perc for oilbased stains. Can handle 

delicate garments. 

EcoSolv 26-27 Less aggressive than Perc for oilbased stains. Can handle 

delicate garments. 

DF-2000 27 Less aggressive than Perc for oilbased stains. Can handle 

delicate garments 

Green Jet 

(DWX-44 detergent) 

N/A Less aggressive than Perc. 

More effective in cleaning sugar, 

salt, perspiration stains. Good 

for delicates. Not good for 

heavily soiled garments. 

Rynex 3 70 Aggressive, cleans water-soluble 

and oil-based stains. 

GreenEarth <20 Less aggressive than Perc for oilbased stains. Good for 

water-based stains, delicates. 

CO2 <101 Good for all stains and most 

fabrics. Very effective in 

removing oils, greases, sweats. 

Wet cleaning N/A Aggressive, good for both oil and 

water-based stains. Can handle 

delicate garments. 

1. KB value depends on machine. Lowering temperature provides for a higher KB value. 
 IX-1

IX. REFERENCES 

ARB, 1993. Staff Report: Proposed Airborne Toxic Control Measure and Proposed 

Environmental Training Program for Perchloroethylene Dry Cleaning Operations. 

California Air Resources Board, August 27, 1993. 

ARB, 1993a. Technical Support Document: Proposed Airborne Toxic Control Measure 

and Proposed Environmental Training Program for Perchloroethylene Dry Cleaning 

Operations, California Air Resources Board, August 27, 1993. 

ARB, 1996. Curriculum for the Environmental Training Program for Perchloroethylene 

Dry Cleaning Operations, California Air Resources Board, April 1996. 

ARB, 1997. Toxic Air Contaminant Identification List – Summaries, California Air 

Resources Board, September 1997. 

ARB, 2003. Dry Cleaning ATCM Evaluation Workgroup Meeting, July 10, 2003. 

ARB, 2004. E-mail from Greg Collins, Chevron Phillips Chemical Company to 

Sonia Villalobos, ARB, August 16, 2004. 

ARB, 2004a. Dry Cleaning ATCM Evaluation Workgroup Meeting, September 21, 2004. 

ARB, 2004b. E-mails from Kelly Kelleher, Kelleher Equipment to Sonia Villalobos, ARB, 

October 2004. 

ARB, 2004c. CAPCOA Enforcement Manager's Meeting, April 15, 2004. 

ARB, 2004d. Telephone conversation with Workgroup Supply representative and 

Sonia Villalobos, ARB, 2004. 

ARB, 2004e. E-mail from Dr. Nancy W. Eilerts, Chevron Philips Chemical Company to 

Mei Fong, ARB, January 2004. 

ARB, 2004f. Feori Wet Cleaning System brochure from Future Clean U.S.A. 

ARB, 2004g. Resolve Drycleaning System company presentation, summary document 

for U.S. EPA and an e-mail from Eileen Sheehan, U.S. EPA to Mei Fong, ARB, 

March 19, 2004. 

ARB, 2004h. E-mail from Steve Risotto, Halogenated Solvents Industry Alliance, 

February 4, 2004. 

ARB, 2004i. Telephone conversation with Katy Wolf, January 4, 2004. 
 IX-2

ARB, 2005. E-mail from Peter Sinsheimer, Director of Pollution Prevention Education 

and Research Center, February 11, 2005. 

ARB, 2005a. Dry Cleaning ATCM Evaluation Workgroup Meeting, June 16, 2005. 

ARB, 2005b. Telephone Conversations with Technichem and Safety Kleen 

representatives, June 21, 2005. 

ARB, 2005c. Dry Cleaning ATCM Evaluation Workgroup Meeting, July 13, 2005. 

ARB, 2005d. E-mail from James Douglas, GreenEarth, July 20, 2005. 

ARB, 2005e. E-mail from Steve Risotto, Halogenated Solvents Industry Alliance, 

August 5, 2005. 

ARB, 2005f. Lyondell Chemical Company, Impress Solvent Questions and Answers 

(2652), 2004. Website at http://www.lyondell.com/html/products/techlit/2652.pdf 

ARB, 2005g. Telephone Conversation with Bob Blackburn, October 18, 2005. 

AVES, 2000. The Assessment of the Effectiveness of Room Enclosures with 

Ventilation Systems in Reducing Risk at Dry Cleaning Facilities Using 

Perchloroethylene. AVES, an Affiliated of ATC Associates Inc., July 14, 2000. 

Begley, 2004. E-mail from Reg Begley, Sail Star, October 20, 2004. 

BLS, 2004. Bureau of Labor Statistics, U.S. Department of Labor, Consumer Price 

Index, 2004. 

CDHS, 2003. California Department of Health Services (CDHS), 2003 Health Hazard 

Alert, Hazard Evaluation System and Information System, 1-Bromopropane, July 2003. 

CFCA, 2002. Coalition for Clean Air, Hung Out to Dry: How the Use of 

Perchloroethylene in Dry Cleaning Endangers You and Your Family’s Health, 

October 2002. 

Chevron Phillips, 2005. Letter to Ms. Mei Fong regarding California Dry Cleaning 

Industry Technical Assessment Rport. November 22, 2005. 

Cleaners Family, 2004. Cleaners Family, Miracle Solvents? Evaluation of Hydrocarbon, 

GreenEarth, PureDry vs Perc; The Secrete of the Amazing Cleaning Results by 

Alternative Solvents, Volume 4, No. 1, February 2004. 

ExxonMobil, 2003. Product Environmental Profile, DF-2000TM Fluid, ExxonMobile 

Chemical, January 9, 2003. 
 IX-3

GreenEarth, 2003. Memo from Jim Barry, Chairman of GreenEarth Cleaning to 

Affiliates, Friends and Associates regarding GreenEarth Cleaning Safety Update. 

March 19, 2003. 

IFI, 2002. Research Fellowship, GreenEarth Fellowship, Copyright International 

Fabricare Institute, No. F-47, September 2002. 

IRTA, 2005. Evaluation of New and Emerging Technologies for Textile Cleaning, 

Institute for Research and Technical Assistance, August 2005. 

JE, 2004. Viable Alternatives to Perchloroethylene in Dry Cleaning, Jacobs 

Engineering, Prepared for City of Los Angeles, December 30, 2004. 

JOEH, 2005. A Proposed Methodology for Setting Occupational Exposure Limits for 

Hydrocarbon Solvents, Journal of Occupational and Environmental Hygiene, Richard H. 

McKee, et al., October 2005. 

Kelleher, 2004. A Technical and Practical Study of Tonsil Filter Aid, Everett Childers, 

2004. 

Material Safety Data Sheets for Rynex (2004), Stoddard (1997), PureDry (2002), Shell 

140 (1992), DF-2000 (2000), and EcoSolv (2003). 

NC, 2001. Alternatives to the Predominant Dry Cleaning Processes, North Carolina 

Department of Environment and Natural Resources, October 2001. 

NTP, 2004. NTP Technical Report on the Toxicology and Carcinogenesis Studies of 

Stoddard Solvent IIC In F344/N Rats and B6C3F1 Mice, National Toxicology Program. 

September, 2004. 

OEHHA, 2003. Memo from George Alexeeff to Peter Venturini regarding health effects 

of exposure to alternative dry cleaning solvents, December 2, 2003. 

PG&E, 2005. Pacific Gas and Electric Company rates for June 2005. 

PPERC, 1999. Switching to Pollution Prevention, Prevention Education and Research 

Center, April 1999. 

PPERC, 2002. Commercialization of Professional Wet Cleaning: An Evaluation of the 

Opportunities and Factors Involved in Switching to a Pollution Prevention Technology in 

the Garment Care Industry, Pollution Prevention Education and Research Center, 

October 28, 2002. 

PPERC, 2003. Memorandum, Subject: Current Assessment of Green Jet Garment 

Cleaning System, Pollution Prevention Education and Research Center, April 11, 2003. 
 IX-4

PPERC, 2004. Professional Wet Cleaning Equipment Report, Pollution Prevention 

Education and Research Center, March 11, 2004. 

PPERC, 2004a. Evaluating Energy Efficiency in the Garment Care Industry: A 

Comparison of Five Garment Care Technologies, Pollution Prevention Education and 

Research Center, September, 2004. 

Rynex, 2005. Rynex Environmental Dry Cleaning Solutions Website, www.rynex.com. 

Rynex 2005a. The Facts about Rynex the Proven Alternative Solvent, www.rynex.com 

SIDS, 2003. SIDS Initial Assessment Report For SIAM 17, November 2003. 

Smerling, 2004. Telephone conversation with Bob Smerling, October 29, 2004. 

SMUD, 2005. General Service Rate Schedules, Sacramento Municipal Utility District, 

March 3, 2005. 

South Coast, 2002. Final Staff Report - Proposed Amendment Rule 1421 - Control of

Perchloroethylene Emissions from Dry Cleaning Systems, South Coast Air Quality 

Management District, October, 2002. 

U.S. EPA, 1998. Cleaner Technologies Substitutes Assessment: Professional 

Fabricare Processes. Design for the Environment, June 1998. 

U.S. EPA, 1999. Case Study: Liquid Carbon Dioxide (CO2) Surfactant System for 

Garment Care, Design for the Environment. 

www.epa.gov/opptintr/dfe/pubs/garment/lcds/micell.htm. May 1999. 

U.S. EPA, 2003. Siloxane D5 in Drycleaning Applications, Fact Sheet, August 2003. 
Appendix A

Dry Cleaning Facility Survey
Winston H. Hickox

Agency Secretary

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption.

For a list of simple ways you can reduce demand and cut your energy costs, see our Website: http://www.arb.ca.gov.

California Environmental Protection Agency

Printed on Recycled Paper

Air Resources Board

Alan C. Lloyd, Ph.D.

Chairman

1001 I Street • P.O. Box 2815 • Sacramento, California 95812 • www.arb.ca.gov

Gray Davis

Governor

September 16, 2003

Dear Dry Cleaning Professional:

The Air Resources Board (ARB), in cooperation with the California Cleaners Association,

the Korean Dry Cleaners-Laundry Association, other industry representatives, and the

local air districts, has developed the Dry Cleaning Facility Survey (Survey). Please note

that this Survey is different from other surveys or information requests that you may have

received from your local air district or other government agencies. We are asking each dry

cleaning facility to complete and return the enclosed Survey.

The Survey has two parts. Part 1 of the Survey requests general information about your

dry cleaning business. Part 2 of the Survey requests more detailed information about the

type and operation of your dry cleaning machine. If you have more than one machine,

please make copies of Part 2 and fill out one Part 2 per machine. Please complete the

enclosed Survey and return it to us using the enclosed postage paid envelope by

October 10, 2003 at the address shown below:

 Attention SSD Dry Cleaning Survey

 State of California

 Air Resources Board

 P.O. Box 2815

 Sacramento, CA 95812-9987

Please be advised that your responses on the Survey will be kept confidential. No

information specifically identifying your facility will be published or distributed by ARB. We

are providing the Survey and this letter in both English and Korean (the Korean translation

is on the reverse side). We ask that all responses or correspondence be in English (if

possible).

If you are not a dry cleaner, please complete the Company Information area (question 1,

Page 1), write “not a dry cleaner” in the Comments area (question 6, Page 2), and return

the Survey to us.

Why is the ARB asking me to complete and return this survey?

The ARB is currently conducting a statewide assessment of the California dry cleaning

industry. The purpose of the assessment is to improve our understanding of the various

technologies being used in the dry cleaning industry and to collect information regarding

cost, efficacy, and environmental impact of those technologies. The enclosed survey is an
A-2

Dry Cleaning Professional

September 16, 2003

Page 2

important part of this assessment. The information obtained during the assessment will

help us determine the effectiveness of the current statewide Airborne Toxic Control

Measure for Emissions of Perchloroethylene from Dry Cleaning Operations (Dry Cleaning

ATCM) and whether the Dry Cleaning ATCM continues to be adequately protective of

public health.

Why does the ARB need economic information about my business?

While conducting the assessment, we want to ensure that we have a reasonable

understanding of how the various technologies may affect your business economically.

Without specific information from you and other dry cleaners in California, we would need

to use nationwide estimates that may not be as accurate as the information you provide.

Does the ARB have the legal authority to request the information on the Survey?

Yes. State law (Health and Safety Code, section 39660) authorizes the ARB to request

and gather information needed to evaluate toxic air contaminants, such as

perchloroethylene (Perc), and other substances. The ARB listed Perc as a toxic air

contaminant in October 1991.

When do I need to return the Survey?

We are requesting that you return the Survey to us by October 10, 2003. In appreciation

for returning the Survey to us by this date, you will automatically be entered into a drawing

for one of five FREE environmental training classes.

Thank you in advance for your assistance in providing us this information. If you have any

questions or comments, please do not hesitate to contact Hafizur Chowdhury at

(916) 322-2275, Sonia Villalobos at (916) 327-5983, or Mei Fong at (916) 324-2570.

Sincerely,

Richard Boyd, Manager

Emissions Evaluation Section

Stationary Source Division

Enclosure

cc: See next page.
A-3

Dry Cleaning Professional

September 16, 2003

Page 3

cc: Hafizur Chowdhury

Air Resources Engineer

Emissions Evaluation Section

Sonia Villalobos

Air Pollution Specialist

Emissions Evaluation Section

Mei Fong

Air Resources Engineer

Emissions Evaluation Section
Winston H. Hickox

Agency Secretary

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a

list of simple ways you can reduce demand and cut your energy costs, see our Website: http://www.arb.ca.gov.

California Environmental Protection Agency

A-4

Air Resources Board

Alan C. Lloyd, Ph.D.

Chairman

1001 I Street • P.O. Box 2815 • Sacramento, California 95812 • www.arb.ca.gov

Gray Davis

Governor

September 12, 2003

드라이 크리닝업 종사자 분들께:

대기자원 관리국(ARB)에서는, 켈리포니아주 세탁협회, 한인 드라이 크리너세탁협회, 그 외 관계 된 기타 업계 대표, 그리고 대기 관리 지역사무소의 협조아래

여기 동봉하는 질문서를 제작하였음니다. 이 질문서는 대기 관리 지역사무소나 다른

정부기관에서 실시한 질문서나 정보 요청서와는 다릅니다. 저희는 크리닝업 종사자

분들께서 이 질문서에 답변 후 제출하여주시기를 부탁드립니다.

여기에 동봉하는 드라이 크리닝에 관한 질문서는 두 부분으로 나누어저있읍니다.

첫 부분은 귀 업소에 관한 일반적인 질문입니다. 두번째 부분은 현 기계의 종류

및 가동상태에 대한 좀더 세부적인 질문입니다. 만약 세탁기게를하나이상

소유하고계실경우, 질문서의두번째부분을복사하여각세탁기계당하나씩

제출해주십시요. 동봉한 질문서에 답변하여서 October 10, 2003 까지 아래주소로

제출하여 주시기를 부탁드립니다.

Attention SSD Dry Cleaning Survey

State of California

Air Resources Board

P.O. Box 2815

Sacramento, CA 95812-9987

귀하의 답변내용은 기밀로 보장됩니다. ARB는 귀하의 업소가 타인에게

밝혀질만한 자료는 발표하거나 분포하지 않을것입니다. 영어와 한국어로 번역된

질문서와 편지를 보내드립니다 (한국어 번역은 뒷면). 대기자원관리국으로 보내는

모든 편지와 답변은 가능한 영어로 작성해 주시기바랍니다.

귀하의 업소에서 드라이 크리닝을하지않을 경우, 첫번째 페이지 1번 업소조사 란에

답하신 후, 두번째 페이지 6번 기타사항 란에 “드라이 크리닝을하지않음.” 이라고 쓰신

후에 제출하여주시기를 부탁드립니다.

대기자원관리국에서 나의 도움이 필요한 이유는 무엇입니까?

ARB는 현제 켈리포니아 드라이 크리닝업소를 평가하려합니다. 이번 평가의

목적은, 드라이 크리닝업소에서 사용하는 기술에대한 저희의 이해를높이고 또, 그런

기술에 드는 비용과 효율성에대한 정보를 얻기위합입니다. 동봉한 질문서는 이번
A-5

드라이 크리닝업 종사자 분들께

Page 2

평가에 쓰일 중요한 자료입니다. 이번 평가 자료는 현제의 드라이

크리닝업체로부터 대기에 유출되는 독성 물질 펄크 규제법안 (Dry Cleaning

ATCM)의 유효성과, 또 이 법안 이 적합한 공중보건안으로 계속 쓰일수 있는지

결정하는데 도움이 될것입니다.

대기자원관리국은 왜 나의 업소 경영정보를 필요로 합니까?

저희는 이번 평가를 통하여, 여러가지 다양한 기술이 귀하의 사업에 미치는 경제적

영향에 대하여 저희가 잘 알고있는지 확인하고자 합니다. 귀하와 기타

켈리포니아에서 드라이 크리닝업에 종사하시는 분들로부터의 자료없이는 전국으로

통용되는 예산치를 기준으로 사용하게됨으로 귀하께서 제공하는 자료만큼 정확한

정보가 될수 없을 것입니다.

대기자원관리국이 질문서에서 요구하는 정보를 요청할수있는 법적인 근거를 가지고

있읍니까?

네. 켈리포니아주 법률(보건 및 안전에 관한 법 제 39660 조) 에 의하여 ARB 는

펄크 (Perc)와 같은 유해한 대기오염물질을 관리규정하는데 필요한 정보를 요구하고

수집할 권한이 있읍니다. 대기자원관리국은 펄크 (Perc) 를 유해한 대기오염물질로

1991년 10월에 지정하였읍니다.

이 질문서는 언제까지 제출하여야 합니까?

October 10, 2003 까지보내 주시기를 바랍니다. 날짜안에 제출하여 주시는것에 대한

감사의 뜻에서, 제출하신분 중 다섯 분을 추첨하여 드라이 크리닝 환경 연수교육을

무료로 드림니다. 

저희의 자료수집에 도움 주신것에대하여 미리 감사드립니다. 이 드라이크리닝

질문서에대해 의문이 있거나 작성에 도움이 필요할경우, 주저없이 Hafizur Chowdhury

(916) 322-2275, Sonia Villalobos (916) 327-5983 또는, Mei Fong (916) 324-2570 에게

연락해주십시요.

Sincerely,

Richard Boyd, Manager

Emissions Evaluation Section

Stationary Source Division
A-6

드라이 크리닝업 종사자 분들께

Page 3

Enclosure

cc: Hafizur Chowdhury

Air Resources Engineer

Emissions Evaluation Section

Sonia Villalobos

Air Pollution Specialist

Emissions Evaluation Section

Mei Fong

Air Resources Engineer

Emissions Evaluation Section
QUESTIONS AND ASSISTANCE

Hafizur Chowdhury Sonia Villalobos Mei Fong

Phone: (916) 322-2275 Phone: (916) 327-5983 Phone: (916) 324-2570

E-mail: hchowdhu@arb.ca.gov E-mail: svillalo@arb.ca.gov E-mail: sfong@arb.ca.gov

Please return the completed survey by October 10, 2003 and mail to:

Attention SSD Dry Cleaning Survey

California Air Resources Board

P. O. Box 2815

Sacramento, CA 95812

1. COMPANY INFORMATION (do not include personal residential address)

Company Name

Contact Person Facility Address

Phone Number City, State, Zip

Fax Number Mailing Address

E-mail Address City, State, Zip

How long have you owned the facility? ______ Years ______ Months 

Do you dry clean on-site? Yes [ ] No [ ] If no, please provide contact information of the dry cleaning facility you send your 

clothes to in number 6 (comments area on page 2) and return the survey to us.

How many total dry cleaning machines are in the facility? Perc ______ Non-Perc ______

If facility is a chain operation: Owner's name _______________________ Phone (_____)_____________

Annual Receipts From Total Operation : 

Percent Annual Receipts From Dry Cleaning Only: 

Less than 25% [ ] 25-50% [ ] 50-75% [ ] more than 75% [ ]

Total Facility Employees:

Business Hours:

Saturday ____ AM to ____ PM

Sunday ____ AM to ____ PM

PART 1

Date

If you return the completed survey by October 10, 2003, you will automatically be entered into a drawing for one of five FREE 

Dry Cleaning Environmental Training Classes.

DRY CLEANING FACILITY SURVEY

( )

Business Status: Independently Owned [ ] Chain Operation [ ] Franchise [ ]

Survey responses will be kept confidential as provided under California law

Thank you for taking the time to complete this survey. Please be advised that the survey has two parts (Part 1 and Part 2) 

and your response on both parts is appreciated. If you have any questions about the dry cleaning facility survey or need 

assistance in completing the survey, please feel free to contact any of the following staff:

Less than $100,000 [ ] $100,001 - $500,000 [ ] $500,001 - above [ ] 

Full Time ______ Part Time ______ Average Part Time Hours/week ______ 

Monday thru Friday ____ AM to ____ PM

( )

2. BUSINESS INFORMATION

Business Type: Plant/Retail [ ] Industrial [ ] Government [ ] Nonprofit [ ] Hotel/Motel [ ] Other [ ]

Survey 2003 A-7 PART 1 - Page 1 of 4
DRY CLEANING FACILITY SURVEY

Solvent Type Used: What do you do with your separator water?

Perc [ ] Water (wet cleaning) [ ] Wastewater treatment unit [ ]

DF-2000 [ ] Green Jet [ ] -Type: Evaporator [ ]

Rynex [ ] Pure Dry [ ] Atomizer [ ] Liquid Discharge [ ]

Stoddard [ ] Eco Solve [ ] -Make __________ Model __________

Green Earth [ ] Liquid CO2

 [ ] Collected by waste hauler [ ]

Other __________________ Discharged to sewer [ ]

Used in a cooling tower [ ]

Used to generate steam [ ]

Other __________________

From whom do you purchase your solvent? 

Company name ____________________________________ Phone (_____)________________

Company name ____________________________________ Phone (_____)________________

Who collects your waste (e.g., still bottoms, separator water, filters)? 

Company name ____________________________________ Phone (_____)________________

Company name ____________________________________ Phone (_____)________________

4. FACILITY INFORMATION (only answer those you know) 

Do people live in the building where your facility is located? Yes [ ] No [ ] If yes, then

 - Do people live above the building? Yes [ ] No [ ] 

 - Do people live next to the building (share a wall with your facility)? Yes [ ] No [ ]

Facility size: 

Area ______ square feet Height ______ feet

Nearest neighbors:

Business ______ feet Residence ______ feet Park ______ feet

School (K-12) ______ feet Day Care ______ feet Hospital ______ feet Senior Community ______ feet

Type of ventilation systems used in dry cleaning facility (check all that apply): 

Wall fan [ ] Powered exhaust fan (ceiling) [ ] Non-powered exhaust fan (ceiling) [ ] Open door [ ] Open window [ ] 

Vapor barrier (room enclosure) around the machine: Yes [ ] No [ ] If yes, is it: Total [ ] Partial [ ]

Do you have a local ventilation system (such as fume/exhaust hood or shroud over machine)? Yes [ ] No [ ] 

5. FUTURE MACHINE PURCHASE/REPLACEMENT (check all that apply)

If you had to purchase or replace a machine today, would you purchase a new or used machine? New [ ] Used [ ] 

What type of solvent would you use for this future machine?

 - Perc [ ] DF-2000 [ ] Rynex [ ] Stoddard [ ] Green Earth [ ] Liquid CO2 [ ] Eco Solve [ ] 

 - Pure Dry [ ] Water (wet cleaning) [ ] Other __________________ 

6. COMMENTS (Optional)

Facility Location:

3. OPERATING INFORMATION (check all that apply)

PART 1 (continued)

Survey 2003 A-8 PART 1 - Page 2 of 4
What year did you purchase your machine? _______________ Did you buy it new or used? New [ ] Used [ ]

Machine brand ______________________ Model __________ Rated Capacity __________ pounds

Average pounds per load ________ Average number of loads per week ________

Total amount of clothes dry cleaned per year (pounds) 2000 ________ 2001 ________ 2002 ________ 

Machine Type: Solvent purchased per Machine (gallons):

Transfer [ ]

Dry-to-dry with primary control [ ] Perc ______ ______ ______

Dry-to-dry with secondary control [ ] DF-2000 ______ ______ ______

Converted (vent to no-vent) [ ] Rynex ______ ______ ______

Wet Cleaning [ ] Stoddard ______ ______ ______

Other ____________________ Green Earth ______ ______ ______

Liquid CO2 ______ ______ ______

Eco Solve ______ ______ ______

Pure Dry ______ ______ ______

Other _____________ ______ ______ ______

Normal machine operating schedule: ______ AM to ______ PM days/week ______ 

B. WASTE INFORMATION

Still Bottoms Removed (gallons) 2000 ______ 2001 ______ 2002 ______

Separator Water Produced (gallons) 2000 ______ 2001 ______ 2002 ______

Filters Used:

(1) Cartridge Number of filters disposed of in:

 (a) Standard (7-inch diameter, 14 inches high) 2000 ______ 2001 ______ 2002 ______

 (b) Split (13-inch diameter, 9 inches high) 2000 ______ 2001 ______ 2002 ______

 (c) Jumbo (13-inch diameter, 18 inches high) 2000 ______ 2001 ______ 2002 ______

(2) Spin-Disk

 Non-Powdered [ ] Powdered [ ]

How often do you inspect the machine?

Daily [ ] Weekly [ ] Monthly [ ] Bi-monthly [ ] Quarterly [ ] Twice a year [ ] Yearly [ ] Never [ ] 

 -What type of leak detector (instruments) is used during inspection? __________

How many certified operators do you have on-site? __________

If your machine has a secondary control, how often do you regenerate the carbon?

According to machine manufacturer's specification [ ]

Machine regenerates carbon automatically [ ]

Never [ ]

Other ____________________

C. MAINTENANCE INFORMATION

 2000 2001 2002

DRY CLEANING FACILITY SURVEY

A. MACHINE INFORMATION

Please Copy and Complete This Page for Each Additional Machine

PART 2

Survey 2003 A-9 PART 2 - Page 1 of 1
문의사항과 도움 

Hafizur Chowdhury Sonia Villalobos Mei Fong

Phone: (916) 322-2275 Phone: (916) 327-5983 Phone: (916) 324-2570

E-mail: hchowdhu@arb.ca.gov E-mail: svillalo@arb.ca.gov E-mail: sfong@arb.ca.gov

질문서에 답변하여서 October 10, 2003 까지 아래주소로 제출하여주시기를 부탁드립니다. 

Attention SSD Drycleaning Survey

California Air Resources Board

P. O. Box 2815

Sacramento, CA 95812

1. 업소 조사 (개인거주지 주소는 쓰지말아주십시요).

업소 이름 

연락처 사람 이름 업소 주소 

전화번호 시, 주, 짚 코드 

팩스 번호 우편물 배달 주소 

이메일 주소 시, 주, 짚 코드 

현 상업 소유기간은 얼마나 됩니까? ______ 년 ______ 월 

현 장소에 드라이 크리닝기계가 있읍니까? 네 [ ] 아니요 [ ] "아니요" 일 경우드라이 크리닝을보내는 

 거래 연락처를 6번 질문칸(기타 사항) 에 써서 이 질문서를 제출해 주십시요. 

현 업소에 있는 총 드라이 크리닝 기계는 몇대입니까? 펄크사용기계 ______ 펄크외 사용 기계 ______

체인형태업소일 경우, 소유주의 이름 _______________________ 전화번호 (_____)_____________

총 연수입: 

총 연수입중 드라이 크리닝수입이 차지하는 비율:

25%이하 [ ] 25-50% 사이 [ ] 50-75% 사이 [ ] 75% 이상 [ ]

종업원 수 :

영업시간 :

토요일 ____ AM 부터 ____ PM 까지

일요일 ____ AM 부터 ____ PM 까지

2. 사업경영 조사

업체 종류: 공장/소매 [ ] 산업체 [ ] 관영 [ ] 비영리법인 [ ] 호텔/모텔 [ ] 기타 [ ] 업체 종류: 

( )

$100,000 이하 [ ] $100,001 - $500,000 사이 [ ] $500,001 이상 [ ] 

풀타임 ______명 파트타임______ 명 평균 파트타임 시간 주 ___ 시간

월요일 - 금요일 ____ AM 부터 ____ PM 까지

드라이크리닝 업소 질문서 

( )

업체소유형태: 개인소유 [ ] 체인형태 소유 [ ] 푸렌차이스 [ ] 업체소유형태: 

답변내용은 켈리포니아 법에의하여 기밀로 보장됩니다. 

시간를 내주셔서 감사합니다. 이 질문서는 두 파트로 나누어저있음을 유의하시고, 두 파트(파트1 과 파트2) 모두에 

응답하여주시기를 부탁드립니다. 이 드라이크리닝 질문서에대해 의문이 있거나 작성에 도움이 필요할경우, 아래 직원에게 

연락해주십시요. 

파트 1

오늘날짜 

이 질문서에 답변하셔서 October 10, 2003 까지 제출하시면, 그중 다섯 분을 추첨하여 드라이 크리닝 환경 연수교육을 

무료로 드림니다. 

Survey 2003 A-10 PART 1 - Page 1 of 2
드라이크리닝 업소 질문서 

사용하는 쏠벤트 종류 : 분리된 물처리는 어떻게하십니까 ?

펄크 [ ] 물 (물세탁) [ ] 폐수처리 장치 [ ]

DF-2000 [ ] Green Jet [ ] -종류 : 증발기 [ ]

Rynex [ ] Pure Dry [ ] 아토마이저 [ ] 액체배수 [ ]

Stoddard [ ] Eco Solve [ ] -상표 __________ 모델 __________

Green Earth [ ] Liquid CO2

 [ ] 폐수처리자가 수거[ ]

기타 __________________ 하수구에 버림 [ ]

냉각수조에 (쿨링타월)에 사용 [ ]

스팀에 사용 [ ]

기타 __________________

쏠벤트구입은 누구에게서 합니까 ?

회사 이름 ____________________________________ 전화번호 (_____)________________

회사 이름 ____________________________________ 전화번호 (_____)________________

폐기물 수거는 누가합니까? 

회사 이름 ____________________________________ 전화번호 (_____)________________

회사 이름 ____________________________________ 전화번호 (_____)________________

4. 건물조사 ( 아는대로 기입해 주십시요.) 

건물내에 사람이 거주합니까 ? 네 [ ] 아니요 [ ] "네" 일경우, 

 - 현업소 바로 윗층에 사람이 거주합니까? 네 [ ] 아니요 [ ] 

 - 담을 같이한 바로 옆건물에 사람이 거주합니까? 네[ ] 아니요[ ] 

업소크기 : 

면적 ______ 스퀘어피트 높이 ______ 피트 

주변지역과의 거리 :

상가 ______피트 주택가 ______피트 공원 ______피트

국민학교 ______ 피트 유아원 ______ 피트 병원 ______ 피트 노인 컴뮤니티 ______ 피트

드라이 크리닝 작업장에 있는 환기시설 (해당사항 모두 표시): 

벽에 고정된 환풍기 [ ] 전동환풍기 (천장) [ ] 통풍기 (천장) [ ] 문을열음 [ ] 창문을 열음 [ ] 

기계주위 습기차단 장치(작업장 내): 네 [ ] 아니요 [ ] "네" 일경우, 전체 [ ] 부분 [ ]

부분환기시설이 있읍니까? (예로, 환기후드나 덮개 ) 네 [ ] 아니요 [ ] 

5. 장래 기계구입/교체 여부 (해당사항 모두 표시)

만약 오늘 당장 세탁기계를 구입이나 교체할 경우, 어느 기계를 선택하시겠읍니까? 새 기계 [ ] 중고 [ ] 

어떤 종류의 쏠벤트를 사용하시겠읍니까? 

 - 펄크 [ ] DF-2000 [ ] Rynex [ ] Stoddard [ ] Green Earth [ ] Liquid CO2 [ ] Eco Solve [ ] 

 - Pure Dry [ ] 물 (물세탁) [ ] 기타 __________________ 

6. 기타 사항 

파트 1 (계속)

건물 위치:

3. 기계 가동 ( 해당사항 모두 표시)

Survey 2003 A-11 PART 1 - Page 2 of 2
몇년도에 이 기계를 구입하셨읍니까? _______________ 새 기계 구입 [ ] 중고 구입 [ ]

기계 상표 ______________________ 모델__________ 용량 __________ 파운드 

평균 한번 세탁 파운드 량 ________ 주 평균세탁 수 ________

년 드라이크리닝한 세탁물의 총 무게 (파운드) 2000 ________ 2001 ________ 2002 ________ 

기계 종류 : 기계당 쏠벤트구입량 (갈론):

트렌스퍼 [ ]

드라이 투 드라이 일차 제어 장치 [ ] 펄크 ______ ______ ______

드라이 투 드라이 이차 제어 장치 [ ] DF-2000 ______ ______ ______

개조된 기계 (배기에서 무 배기용 ) [ ] Rynex ______ ______ ______

물 세탁 [ ] Stoddard ______ ______ ______

기타 ____________________ Green Earth ______ ______ ______

Liquid CO2 ______ ______ ______

Eco Solve ______ ______ ______

Pure Dry ______ ______ ______

기타 _____________ ______ ______ ______

기계가동 시간 : ______ AM 부터 ______ PM 까지 주당 ______일 

B. 폐기물 조사

증류기 바닥에서 제거된 폐기물 양 (갈론) 2000 ______ 2001 ______ 2002 ______

분리기에서 나온 물 (갈론) 2000 ______ 2001 ______ 2002 ______

사용하는 필터:

(1) 카트리지 소모한 필터 수 :

 (a) 스탠다드 (지름 7인치, 길이14 인치 ) 2000 ______ 2001 ______ 2002 ______

 (b) 스프릿(지름13인치, 길이9인치) 2000 ______ 2001 ______ 2002 ______

 (c) 점보 (지름 13인치, 길이18 인치) 2000 ______ 2001 ______ 2002 ______

(2) 스핀 디스크 

 파우더가 아닌 종류 [ ] 파우더 종류 [ ]

얼마나 자주 기계정비를 합니까? 

 매일 [ ] 매주한번 [ ] 매월한번 [ ] 두달마다 [ ] 세달마다 [ ] 일년에두번 [ ] 매년 한번 [ ] 안함 [ ] 

 -기계정비 과정중, 누수조사는 어떻게(무슨점검 기계로) 확인 하십니까? __________

작업장에 정식허가받은 기계가동자가 몇 명이 있읍니까? __________

이 기계에 이차 제어 장치가 있으면, carbon(카본)은 얼마나 자주 재 생산합니까? 

 기계제작 회사의 설명서에 따라서 [ ]

 기계가 자동으로 카본생산 [ ]

 안함 [ ]

 기타 ____________________

C. 정비 조사 

 2000 2001 2002

드라이크리닝 업소 질문서 

A. 기계 조사 

이 페이지를 복사하여서 각 기계당 한장씩 작성 제출해 주십시요 . 

파트 2

Survey 2003 A-12 PART 2 - Page 1 of 1
Appendix B

Dry Cleaning Site Visit Survey
Facility Name

Contact Person Street Address

Phone Number City, State, Zip

Fax Number Cross Street

E-mail Address GPS Lat/Long

How long have you own the facility _______________________

Type of business/ Business Status ________________________________

How much do you charge to dry clean a pair of pants? ____________________

Percent of annul receipts from dry cleaning only _____________________

Number of employees both full-time/part-time __________________________

Average part time employee hours per day ________________

Business Hours:

Monday thru Friday ____ AM to ____ PM Saturday ____ AM to ____ PM

Sunday ____ AM to ____ PM

What type of solvent(s) used in the machine(s)? ______________

What do you do with separator water? ___________________________________

From whom do you purchase your solvent? Company _________________ Phone _________

Who collects your waste? Company _______________________ Phone ___________

Do people live in the building where facility is located? _____________________

Do people live above the building? _______________________ 

Do people live next to (share a facility wall) the building? __________________

Area of the facility ________ square feet 

Facility Height _______ feet

Front Door height ________ feet, width ________ feet

Back Door height ________ feet, width ________ feet

Window height ________ feet, width ________ feet

Amount of annual receipt (dollar) from total operation ___________________

2. BUSINESS INFORMATION

3. OPERATING INFORMATION

4. FACILITY INFORMATION 

( )

( )

Date

DRY CLEANING SITE VISIT SURVEY 2003

1. COMPANY INFORMATION

Physical location of the facility __________________________________________ 

Revised: 11/4/03 B-1 Page 1 of 3
DRY CLEANING SITE VISIT SURVEY 2003

Is the facility a part of a larger building? ________________ Stand alone building? ________ 

Dimension of the building: Length ______ feet Width _______ feet Height _______ feet

Does the facility have a stack? ______ 

Stack height ______ feet Stack diameter ______ feet

Does the stack has a raincap/horizontal release? _____ Stack airflow ______ cfm

Does each machine have separate stacks or do they combine into single stack? ______ 

Distance measured from door to door:

Nearest business _____________ feet Residence ______________ feet 

Nearest (School/Day Care/Hospital/Park/Senior Community) _______________________ feet 

What type of fan(s) do you have in your facility? ___________________________

Is there a vapor barrier (room enclosure) around the machine? _________________

Do you still keep your doors open when the weather is bad? _______

If you had to purchase or replace a machine today, would you purchase a new or 

used machine? __________________

What type of solvent would you use for this future machine? _________________

What do you think of the alternative solvents? (write in comments, section 9)

What year did you purchase your machine? ________ Did you buy it new or used ________

Machine brand type ______________________ Model ________

Rated Capacity ________ pounds Machine age ________

Average pounds per load ______ Average number of loads per week ______

Total amount of clothes dry cleaned per year (pounds) 2000 _____ 2001 _____ 2002 _____ 

Have you done any retrofit to the machine? ________________________

Does machine have a shroud? _________ Does machine have a lock-out device? _________

How much solvent used per machine(gallons) in year 2000 _____ 2001 _____ 2002 _____

What is your normal machine operating hours? ______ AM to ______ PM

How many days do you operate the machine per week? _____________

In a year, how many times do you have a minor spill of solvent? _________________

In a year, how many times do you have a major spill of solvent?____________________

6. MACHINE INFORMATION

4. FACILITY INFORMATION (continued)

5. FUTURE MACHINE PURCHASE/REPLACEMENT 

Revised: 11/4/03 B-2 Page 2 of 3
DRY CLEANING SITE VISIT SURVEY 2003

How much still bottoms (gallons) removed in year 2000 ______ 2001 ______ 2002 ______

How much separator water (gallons) produced in year 2000 _____ 2001 ______ 2002 ______

What type of cartridges do you use in your machine? (e.g.: standard, split or jumbo) ________

What do you do in preparation to changing the filters? ______________________________

How do you dispose of the filters? ____________________________________________

How many filters disposed in year 2000 _____ 2001 _____ 2002 _____

If your machine needs Spin-Disk filter, then is it powdered or non powdered? _________

How often do you inspect the machine? ______________

What type of leak detector used during inspection? ________________________

In a year, how many time is a leak being detected? ______________________

Do you have extra gaskets handy?_________

How often do you replace gaskets? _________________________

How many certified operators do you have on-site? ___________

If your machine has a secondary control, how often do you regenerate the carbon? ________

9. COMMENTS

8. MAINTENANCE INFORMATION

7. WASTE INFORMATION

Revised: 11/4/03 B-3 Page 3 of 3
Appendix C

Machine Manufacturer’s Survey
QUESTIONS AND ASSISTANCE

Hafizur Chowdhury Sonia Villalobos Mei Fong

Phone: (916) 322-2275 Phone: (916) 327-5983 Phone: (916) 324-2570

E-mail: hchowdhu@arb.ca.gov E-mail: svillalo@arb.ca.gov E-mail: sfong@arb.ca.gov

Please return the completed survey by April 30, 2004 and mail to:

Attention SSD Dry Cleaning Survey

California Air Resources Board

P. O. Box 2815

Sacramento, CA 95812

1. COMPANY INFORMATION (do not include personal residential address)

Company Name

Contact Person Facility Address

Phone Number City, State, Zip

Fax Number Mailing Address

E-mail Address City, State, Zip

 a: 

b:

c:

d:

e:

f:

g:

h:

i:

j:

k:

l:

m:

n:

Date

Briefly describe how each modeled machine operates. In addition, specify if and when any part of the machine is 

under pressure or under vacuum. Please use extra sheet as an attachment if necessary. 

MACHINE MANUFACTURER SURVEY

( )

Thank you for taking the time to complete this survey. If you have any questions about the manufacturer survey or need 

assistance in completing the survey, please feel free to contact any of the following staff:

Specify types of machine (for example: Dry-to-dry primary control, Dry-to-dry secondary control, Transfer, Wet 

Cleaning - Washer, Wet Cleaning - Dryer, or others).

Specify gas or steam requirements to operate the machine (for example: average monthly cost ($US) of gas or 

steam generation).

Instruction: The description of each item on page 2 and page 3 are elaborated below to complete the survey accurately:

Specify the solvent types for each machine brand (for example: perc, DF-2000TM, Rynex®

, StoddardTM, Green 

Earth®, Water (wet cleaning), Green JetTM, Pure Dry®, Eco SolveTM, Liquid CO2 or others).

Specify each machine brand (for example: Bowe Permac, Multimatic, Crown, Fluormatic, Lindus etc.).

Specify each model power requirement to operate the machine such as 110V, 220V, Amperes, average hours

Specify each model for its type (for example: P546, 380BC, ML45, RS373, BT37 etc.).

Specify each model rated capacity (for example: 35 lbs, 40 lbs, 45 lbs, 60 lbs etc.).

Provide the cycle time in minutes.

Provide the list price ($US) for each type of machine that is sold in the State of California.

If you have different types of machine maintenance schedule besides daily, weekly, monthly etc., then specify 

under 'Other'.

2. NOTES FOR TABLE ON PAGE 2 AND PAGE 3

( )

Estimated yearly maintenance cost ($US) for each model stated in column 10 of page 2.

Provide the maintance requirements for each model as stated in page 3 (for example: daily, weekly, monthly etc.). 

Specify the type of control equipment for each model.

MachineSurvey 2003 C-1 Page 1 of 4
Solventa 

Type

Machineb 

Brand

Machinec 

Types Modeld

Ratede 

Capacity 

(lbs)

Cyclef 

Time 

(minutes)

Listg 

Machine 

Price ($)

Electricalh 

Requirement

Gas/S

Requir

.

MACHINE MANUFACTURER SURVEY

MachineSurvey 2003 C-2 
Modeld

Every 4th 

Load Daily Weekly Monthly

Every 3 

Months

Every 6 

Months

Every 12 

Months

Othern ____ Othern ____Othern ____ Othern ____Othern ____Othern ____ Othern ____

.

Maintenance Requirementsk

Controll 

Equipments

MACHINE MANUFACTURER SURVEY

MachineSurvey 2003 C-3 
COMMENTS

MACHINE MANUFACTURER SURVEY

MachineSurvey 2003 C-4 Page 4 of 4
Appendix D

Standard Operating Procedure

for the Determination of Tetrachloroethylene in

Dry Cleaning Sludge by Gas Chromatograhy - FID
D-1

Special Analysis Section

Northern Laboratory Branch

Monitoring and Laboratory Division

STANDARD OPERATING PROCEDURE FOR THE

DETERMINATION OF TETRACHLOROETHYLENE IN DRY

CLEANING SLUDGE BY GAS CHROMATOGRAPHY-FID

January 31, 2005, Revision 1.0

DISCLAIMER: Mention of any trade name or commercial product in Method 310 and

associated Standard Operating Procedures does not constitute endorsement or

recommendation of this product by the Air Resources Board. Specific brand names and

instrument descriptions listed in the Standard Operating Procedures are equipment used

by the ARB laboratory. Any functionally equivalent instrumentation can be used.
January 31, 2005, Revision 1.0 D-2 Page 2

1 INTRODUCTION

The procedure follows closely MLD SOP SAS07, with modifications to analyze

perchloroethylene from dry cleaning sludge.

This method is suitable for the determination of the exempt compounds: ethanol

(AP/DO only), acetone, methyl acetate and tetrachloroethylene

(perchloroethylene). Additional analytes are methanol, isopropanol, 1-propanol,

isobutanol, and limonene.

2 SUMMARY OF METHOD

The dry cleaning sludge samples from each machine is collected in triplicate in a

250 milliliter (ml) glass jar. One aliquot is used to determine sample density and

another aliquot is used to determine tetrachloroethylene concentration. The

samples of dry cleaning sludge are prepared as 1:10 wt. / volume dilutions in 1-

methoxy-2-propanol (MPA). After dilution and thorough mixing, the insoluble

material is allowed to settle out, or the sample filtered to remove insoluble material.

The diluted sample is then analyzed on a gas chromatograph equipped with a

flame ionization detector(FID). The data is reported as percent perchloroethylene

in the dry cleaning sludge.

3 INTERFERENCES AND LIMITATIONS

With the potential increase in the number of interfering compounds, overlap of

perchloroethylene’s retention time may occur. Care must be taken to make certain

of the identity of the compound, if possible through gas-chromatography-mass

spectrometry.

4 INSTRUMENTATION AND EQUIPMENT

4.1 Gas Chromatograph (GC) configured with a Flame Ionization Detector (FID),

4.1.1 GC Column: J & W DB-624, 30 m x 0.32 mm I.D. with 1.8 μm film,

4.1.2 GC Parameters are as follows:

Oven Conditions

Initial temperature: 35°C 

Initial time: 5.0 min

Rate: 10°C/min

Final temperature: 200°C

Final time: 1.0 min
January 31, 2005, Revision 1.0 D-3 Page 3

Run time: 22.5 min

Oven equilibration: 0.3 min

Injector temperature: 250°C

Detector temperature: 250°C

Carrier gas (He): 10 psi (26 cm/sec)

DET B FID: ON

EPP B: 9.5 psi @ 35oC

Split Flow: 100 mL/min

4.2 Volumetric Flasks:

4.2.1 10 and 500 ml,

4.3 Rainin Pipettors:

4.3.1 250 μL, 1.0 ml, 2.5 ml with tips,

4.4 Vials and Jars:

4.4.1 20 mL, for standards,

4.4.2 8 mL with PTFE-lined cap, for standards and dilutions,

4.4.3 2 mL with caps, for GC analysis,

4.4.4 250 ml widemouth glass jars with PTFE –lined caps,

4.4.5 15 ml graduated disposable polypropylene conical tubes,

4.5 Analytical Balance:

4.5.1 Sartorious ME215S,

4.5.2 Sartorious MC1,

4.5.3 Sartorious LC6201S,

4.6 Vortex Mixer, variable speed.

5 REAGENTS

5.1 1-Methoxy-2-propanol (MPA), 98%,

5.2 Analyte, tetrachloroethylene, spectrophotometric grade,
January 31, 2005, Revision 1.0 D-4 Page 4

5.3 Stock Standards: The 80 mg/mL stock standard is prepared gravimetrically. 

5.4 Control/Check Stock Solution: A control/check stock solution is prepared

using acetone in MPA. The analyte is weighed in the preparation of the

stock, so the concentration is in g/mL. 

5.5 Helium, grade 5,

5.6 Air, compressed, ultra high purity,

5.7 Hydrogen Generator, Whatman, model 75-32 or equivalent.

6 PROCEDURE

6.1 Sample Collection:

6.1.1 Samples are collected in triplicate from each dry cleaning machine.

6.1.2 Using a long wooden or metal stirring rod, stir the collected sludge to

resuspend the solid material as much as possible.

6.1.3 Using a cup or jar fill a 250 ml jar with the stirred dry cleaning sludge.

6.1.4 Clean the jar, seal the container, and attach the sample identification label.

6.1.5 Repeat this process two more times making sure the sludge is remixed

between each sampling.

6.1.6 Place the triplicate samples in a travel container (such as an ice chest) at

ambient temperature for transport back to the laboratory.

6.2 Sample Preparation:

6.2.1 The collected samples are given a unique identification number and

entered into the laboratory information management system (LIMS).

6.2.2 The samples are stored at ambient temperature prior to analysis.

6.2.3 Density Determination:

6.2.3.1 Tare a polypropylene conical tube (Becton-Dickinson 15 ml) on a top

loading balance.

6.2.3.2 For the determination of water density as a control check, fill the conical
January 31, 2005, Revision 1.0 D-5 Page 5

tube with water and cap making sure no air bubbles are present.

6.2.3.3 Weigh the tube to the nearest 0.00 grams. The tubes will hold

approximately 16 ml when filled to capacity

6.2.3.4 Repeat the water density determination two more times. The average

water density should be 1.0 g/ml.

6.2.3.5 Mix the sludge samples well and aliquot into a pouring beaker. Pour into

a 15 ml conical tube as described in 6.2.3.2.

6.2.3.6 Weigh the tube and record the weight.

6.2.3.7 Repeat the sludge density determination two more times using a clean

tube for each determination.

6.2.3.8 Enter weights in the dry cleaning ATCM spreadsheet. The density is

calculated as weight per 16 mls and recorded in g/ml.

6.2.3.9 The tubes should be disposed in the hazardous waste container.

6.2.4 Tetrachloroethylene Determination:

6.2.4.1 Weigh a one (1) milliliter aliquot of sludge into a 10 ml volumetric flask.

6.2.4.2 Fill to the mark with 1-methoxy-2-propanol.

6.2.4.3 Mix well and transfer into an eight (8) ml disposable vial with a PFTE

lined cap.

6.2.4.4 Transfer an aliquot to a 1.8 ml autoinjector vial.

6.3 Instrument Preparation:

6.3.1 Turn on the main valve for the air cylinder; verify cylinder pressure is above

500 psi. 

6.3.2 Verify helium cylinder pressure is above 500 psi.

6.3.3 Check that the water level in hydrogen generator is above the refill line.

6.3.4 Press the FID igniter on the front of the GC.
January 31, 2005, Revision 1.0 D-6 Page 6

6.4 Analysis Preparation:

6.4.1 Solvent Blank: Prepare solvent blank by filling a GC vial with the same

MPA used to make the dilutions in steps 6.2.2 – 6.2.4. Cap the vial.

6.4.2 Calibration Standards: Prepare the five calibration standards in 10 mL

volumetric flasks as follows:

Concentration Volume of Stock Standard

1.0 mg/mL 0.125 mL

10 mg/mL 1.25

20 mg/mL 2.50

40 mg/mL 5.0

80 mg/mL ----

Bring to volume with MPA, mix thoroughly and place in dilution vials.

6.4.3 Transfer an aliquot of each standard into a GC vial and cap.

6.4.4 Control/Check: Prepare the control/check by diluting 1.0 mL of the

control/check stock standard to 10 mL with MPA. The control is analyzed

after the calibration. The check is run after every ten samples and at the

end of the run. 

6.4.5 Transfer an aliquot of each control/check and sample into appropriately

labeled GC vials and cap. 

6.5 Sample Analysis:

6.5.1 Place vials in the autosampler in the following order: MPA blank,

calibration standards, control/check, and diluted samples. The check

standard is run every tenth sample and at the end of the run. Additional

blanks between standards and samples maybe used if carryover is

suspected.

6.5.2 Calculate the value for each analyte found by dividing the amount from the

report (mg/mL) by the sample dilution weight (see Section 8).

7 QUALITY CONTROL

7.1 An MPA solvent blank must be analyzed for each batch of samples. The

analyte concentration in the blank must be less than 0.1% wt./volume. An

MPA blank is run before the control and each check to prevent carry over

from the previous sample.
January 31, 2005, Revision 1.0 D-7 Page 7

7.2 The correlation coefficient for compounds present in the calibration must be

greater than 0.995. If the calibration fails, the sequence is stopped and

corrective action is implemented.

7.3 A control sample is run after the calibration. The control must fall within the

control limits. If the control is not within the control limits, it may be necessary

to recalibrate and rerun the sequence. 

7.4 A check sample is run after every ten samples and at the end of the run. The

check must fall within the control limits. If one of the checks is out of the

control limits, re-run the check and any samples that follow until the next

check. 

8 CALCULATIONS

The weight fraction of analyte in the product is calculated as follows:

( )

( ) 10 2

sample dilution g

analyte mg / mL Weight Fraction of Analyte −

× 











=
Appendix E

Standard Operating Procedure

For the Determination of DF2000TM in Dry Cleaning Sludge

by Gas Chromatography – Mass Selective Detector
E-1

Special Analysis Section

Northern Laboratory Branch

Monitoring and Laboratory Division

STANDARD OPERATING PROCEDURE FOR THE

DETERMINATION OF DF2000TM IN DRY CLEANING SLUDGE

BY GAS CHROMATOGRAPHY-MASS SELECTIVE DETECTOR

May 24, 2005

DISCLAIMER: Mention of any trade name or commercial product in Method 310 and

associated Standard Operating Procedures does not constitute endorsement or

recommendation of this product by the Air Resources Board. Specific brand names and

instrument descriptions listed in the Standard Operating Procedures are equipment used

by the ARB laboratory. Any functionally equivalent instrumentation can be used.
May 24, 2005 E-2 Page 2

1 INTRODUCTION

This method was developed to look specifically for components of the dry cleaning

solvent DF2000TM. DF2000TM is a complex mixture of C11-C13 isoparaffinic

hydrocarbons containing a low percentage of cycloparaffins.

This method is suitable for the determination of aliphatic hydrocarbons in the range

of decane (C10) to octadecane (C18) with boiling points ranging from 174 to 316

degrees centigrade.

2 SUMMARY OF METHOD

The dry cleaning sludge samples are collected in triplicate in a 250 milliliter (ml)

glass jar. One aliquot is used to determine sample density and another aliquot is

used to determine DF2000TM concentration. The samples of dry cleaning sludge are

prepared as 1:20 wt. / volume dilutions in methylene chloride (MeCl2). After

dilution and thorough mixing, the insoluble material is allowed to settle out, or the

sample filtered to remove insoluble material. The diluted sample is then analyzed

on a gas chromatograph equipped with a mass selective detector (MSD). The data

is reported as percent DF2000TM in the dry cleaning sludge.

3 INTERFERENCES AND LIMITATIONS

Since the method looks for the generic class of hydrocarbons from decane to

octadecane there is an increased likelihood of interference from hydrocarbon

contribution from sources other than the sludge sample. Method blanks should be

analyzed to insure the solvent and instrument are free of hydrocarbon

contaminants.

4 INSTRUMENTATION AND EQUIPMENT

4.1 Gas Chromatograph (GC) configured with a Mass Selective Detector (MSD),

4.1.1 GC Column: J & W DB-1, 60 m x 0.32 mm I.D. with 1.0 μm film,

4.1.2 GC Parameters are as follows:

Oven Conditions

Initial temperature: 40°C 

Initial time: 2.0 min

Rate: 2.0°C/min

Intermediate temperature: 200°C

Intermediate hold time: 5.0 min
May 24, 2005 E-3 Page 3

Rate: 40°C/min

Final Temperature: 320°C

Final Hold Time: 1.0 min

Run time: 91.0 min

Oven equilibration: 0.3 min

Injector temperature: 300°C

Interface temperature: 300°C

Carrier gas (He): 1.46 ml/min

Source Temperature: 150°C

MSD scan range: 40 to 500 amu

Split Flow: Splitless for 1.0 min

4.2 10 ml Volumetric Flasks,

4.3 Rainin Pipettors: 250 μl, 1.0 ml, 2.5 ml with tips,

4.4 Vials and Jars:

4.4.1 8 mL with PTFE-lined cap, for standards and dilutions,

4.4.2 2 mL with caps, for GC-MSD analysis,

4.4.3 250 ml widemouth glass jars with PTFE –lined caps,

4.4.4 15 ml graduated disposable polypropylene conical tubes,

4.5 Analytical Balance capable weighing to 0.1 milligram,

4.6 Vortex Mixer, variable speed.

5 REAGENTS 

5.1 Dichloromethane, Pesticide grade or better,

5.2 DF2000TM directly from the manufacturer or the dry cleaners supply,

5.3 Stock Standards: The 15 mg/mL stock standard is prepared gravimetrically,

5.4 Helium, grade 5.

6 PROCEDURE

6.1 Sample Collection:
May 24, 2005 E-4 Page 4

6.1.1 Samples are collected from eight (8) liter buckets of dry cleaning sludge

which represents the total contents of the dry cleaning machine sump.

6.1.2 Using a long wooden or metal stirring rod, stir the collected sludge to

resuspend the solid material as much as possible.

6.1.3 Using a cup or jar fill a 250 ml jar with the stirred dry cleaning sludge.

6.1.4 Clean the jar, seal the container, and attach the sample identification label.

6.1.5 Repeat this process two more times making sure the sludge is remixed

between each sampling.

6.1.6 If the aliquoted samples are not to be analyzed immediately store either in

a laboratory hood or in a refrigerator.

6.2 Sample Preparation:

6.2.1 The collected samples are entered into the laboratory information

management system (LIMS) and given a unique identification number.

6.2.2 If the samples were stored in the refrigerator allow them to warm to

ambient temperature prior to analysis.

6.2.3 Density Determination:

6.2.3.1 Tare a polypropylene conical tube (Becton-Dickinson 15 ml) on a top

loading balance.

6.2.3.2 For the determination of water density as a control check, fill the conical

tube with water and cap making sure no air bubbles are present.

6.2.3.3 Weigh the tube to the nearest hundreth of a gram. The tubes will hold

16 ml when filled to capacity

6.2.3.4 Repeat the water density determination two more times. The average

water density should be 1.0 g/ml.

6.2.3.5 Mix the sludge samples well and aliquot into a pouring beaker. Pour into

a 15 ml conical tube as described in 6.2.3.2.

6.2.3.6 Weigh the tube and record the weight.

6.2.3.7 Repeat the sludge density determination two more times using a clean

tube for each determination.
May 24, 2005 E-5 Page 5

6.2.3.8 Enter weights in the dry cleaning ATCM spreadsheet. The density is

calculated as weight per 16 mls and recorded in g/ml.

6.2.3.9 The tubes should be disposed in the hazardous waste container.

6.2.4 DF2000TM Determination:

6.2.4.1 Weigh approximately 0.5 ml of sludge into a 10 ml volumetric flask. 

6.2.4.2 Fill to the mark with MeCl2.

6.2.4.3 Mix well and transfer into an eight (8) ml disposable vial with a PFTE

lined cap. Allow the solids to settle out before analysis.

6.2.4.4 Make a serial dilution such that the final concentration of sludge is in the

three (3) to five (5) milligram per milliliter range.

6.2.4.5 Transfer an aliquot to a 1.8 ml autoinjector vial.

6.3 Instrument Preparation:

6.3.1 Verify helium cylinder pressure is above 500 psi.

6.3.2 Load the Exxon method into the GC/MSD.

6.3.3 After system equilibrates TUNE the MSD using the Standard Tune

command. 

6.3.4 After tuning the MSD check to insure the calibration is acceptable.

6.4 Analysis Preparation:

6.4.1 Solvent Blank: Prepare solvent blank by filling a GC vial with the same

MeCl2 used to make the dilutions in steps 6.2.2 – 6.2.4. Cap the vial.

6.4.2 Calibration Standards: Prepare the five DF2000TM calibration standards in

10 mL volumetric flasks as follows:

Concentration Volume of Stock Standard

0.1 mg/mL 0.0665 mL

0.2 mg/mL 0.133

0.5 mg/mL 0.333

1.0 mg/mL 0.667

2.0 mg/mL 1.333
May 24, 2005 E-6 Page 6

Bring to volume with MeCl2, mix thoroughly and place in dilution vials.

6.4.3 Transfer an aliquot of each standard into a GC vial and cap.

6.5 Sample Analysis:

6.5.1 Place vials in the autosampler in the following order: MeCl2 blank,

calibration standards, continuing calibration verification, and diluted

samples. The continuing calibration verifcation standard is run every tenth

sample and at the end of the run. Additional blanks between standards

and samples maybe used if carryover is suspected.

6.5.2 Calculate the value for each analyte found by dividing the amount from the

report (mg/mL) by the sample dilution weight (see Section 8).

7 QUALITY CONTROL

7.1 An MeCl2 solvent blank must be analyzed for each batch of samples. The

analyte concentration in the blank must be less than 0.1 mg/ml. An MeCl2

blank is run before the control and each check to prevent carry over from the

previous sample.

7.2 The correlation coefficient for compounds present in the calibration must be

greater than 0.995. If the calibration fails, the sequence is stopped and

corrective action is implemented.

7.3 A continuing calibration verification (CCV) sample is run after every ten

samples and at the end of the run. The CCV must fall within +/- 25% of the

true value. If one of the CCV’s is out of the control limits, re-run the CCV and

any samples that follow until the next acceptable CCV.

8 QUANTIFICATION

8.1 Because DF2000TM is a complex mixture, seven (7) peaks are used to

represent the entire complex mixture during quantitation. The peaks are

identified as Peaks 1 through 7.

8.2 Peaks 1 through 7 are identified by retention times which are listed in Table 1.
May 24, 2005 E-7 Page 7

Table 1

Peak

Number

Retention Time

(mins)

1 40.24

2 41.26

3 43.00

4 43.45

5 44.52

6 48.20

7 51.72

8.3 The weight fraction of Peaks 1 through 7 in the sludge are calculated as follows:

8.4 These seven peaks are then reported as the average of peaks 1 through 5, peaks

6 and 7, and peaks 1 through 7.

( )

( ) 10 / −2

× 















=

sample dilution g

analyte mg mL Weight Fraction of Analyte
Appendix F

Sludge Sampling Results
F-1

Table F-1. Perc Sludge Test Results (Primary Machines)

Machine Test

No.

Make Model

Year

Sludge

Density

(g/ml)

Sludge

Density

(lb/gal)

%

solvent

in

sludge

# of

filter

Machine A 1 Bowe Permac 1994 1.20 10.00 44 0

Machine A 2 Bowe Permac 1994 1.13 9.39 17 0

Machine A 3 Bowe Permac 1994 1.08 9.03 18 0

Machine B 1 Bowe Permac 1991 1.08 9.03 21 0

Machine B 2 Bowe Permac 1991 1.07 8.95 14 0

Machine B 3 Bowe Permac 1991 1.07 8.92 11 0

Machine C 1 Bowe Permac 1999 1.02 8.50 14 0

Machine C 2 Bowe Permac 1999 1.16 9.70 29 0

Machine D 1 Midwest 1988 1.37 11.45 67 0

Machine D 2 Midwest 1988 1.20 10.00 41 0

Machine D 3 Midwest 1988 1.33 11.06 69 0

Machine E 1 Columbia 1993 1.26 10.50 61 0

Machine E 2 Columbia 1993 1.17 9.78 39 0

Machine E 3 Columbia 1993 1.30 10.81 65 0

Machine F 1 Columbia 2000 1.18 9.84 40 0

Machine F 2 Columbia 2000 1.09 9.09 31 0

Machine F 3 Columbia 2000 1.11 9.25 33 0
F-2

Table F-2. Perc Sludge Test Results (Secondary Machines)

Machine Test

No.

Make Model

Year

Sludge

Density

(g/ml)

Sludge

Density

(lb/gal)

%

solvent

in

sludge

# of

filter

Machine A,B11 Columbia 1997 1.19 9.92 43 0

Machine A,B12 Columbia 1997 1.21 10.09 51 0

Machine A,B13 Columbia 1997 1.20 9.98 41 0

Machine C 1 Victory 1996 1.20 10.00 45 3

Machine C 2 Victory 1996 1.17 9.75 38 3

Machine C 1 Victory 1986 1.15 9.56 44 3

 1. Machines A and B have a common still.
F-3

Table F-3. DF-2000 Sludge Test Results

Machine ID Test

No.

Make Model

Year

Sludge

Density

(g/ml)

Sludge

Density

(lb/gal)

%

solvent

in

sludge

# of

filter

Machine A 1 Realstar 1997 0.898 7.49 26 12

Machine A 2 Realstar 1997 0.892 7.44 29 12

Machine A 3 Realstar 1997 0.891 7.43 24 12

Machine B 1 Realstar 2003 0.920 7.67 12 10

Machine B 2 Realstar 2003 0.922 7.68 11 10

Machine B 3 Realstar 2003 0.913 7.61 15 10
Appendix G

OEHHA Memorandum























































Appendix H 

Laboratory Evaluation of Leak Detectors
Alan C. Lloyd, Ph.D. 

Agency Secretary

 

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. 

For a list of simple ways you can reduce demand and cut your energy costs, see our Website: http://www.arb.ca.gov. 

California Environmental Protection Agency

Printed on Recycled Paper

Air Resources Board 

 

1001 I Street • P.O. Box 2815 

Sacramento, California 95812 • www.arb.ca.gov 

Arnold Schwarzenegger

 Governor 

MEMORANDUM 

TO: Richard Boyd, Manager 

 Emissions Evaluation Section 

 Stationary Source Division 

FROM: Dennis Goodenow, Manager 

 Source Testing Section 

 Monitoring and Laboratory Division 

DATE: October 3, 2005 

SUBJECT: Portable VOC Analyzer Evaluations 

At the request of the Emissions Evaluation Section (EES), the Monitoring and 

Laboratory Division Source Testing Section (STS) is engaged in ongoing evaluations of 

portable VOC analyzers. The evaluations are intended to compare responses from 

analyzers of varying cost and detection principles to perchloroethylene (PERC) gas 

calibration standards. Stationary Source Division is considering amendment of the 

vapor leak threshold in the ATCM for PERC emissions from dry cleaning operations. 

An initial, qualitative evaluation of two low cost analyzers was performed 

October 4, 2004 at the Source Testing Section facility at 1301 V Street in Sacramento. 

Results for this evaluation were reported to the Emissions Evaluation Section in an 

October 28, 2004 memorandum. However, the results are of questionable validity 

because they were produced using a non-traceable PERC standard with an assumed 

concentration of 50 ppmv. STS has since procured certified, traceable dry calibration 

standards of 25 ppmv PERC, 50 ppmv PERC and 100 ppmv isobutylene. EES has also 

identified eight additional portable analyzers and presented them to STS for evaluation. 

The analyzers range in sophistication from semiconductor sensors with audible alarms 

costing approximately $200.00 to photoionization detectors with LCD displays costing in 

excess of $3,000.00. The ten analyzers and their respective principles of operation are 

identified in Table 1. 

The h⋅nu Systems HW-101 was the designated reference analyzer for this survey based 

on its availability and photoionization detector (PID). The other PID analyzers used in 

the survey were available to EES on a temporary basis. The HW-101 analog display is 

also motion sensitive, making it impractical for field use as a leak detection tool. 

Although the HW-101 display is a relatively unsophisticated analog potentiometer, it 
H-2

produced repeatable PERC concentration values in the 0 – 200 ppmv range when 

calibrated against the 100 ppmv isobutylene standard. HW-101 calibration was 

examined, and adjusted if necessary, before beginning each evaluation session. 

Table 1 

Portable VOC Analyzers Evaluated for PERC Response 

Model and (Manufacturer) Detection 

Principle 

Sample 

Delivery Display 

Gas Alert Micro 5 

(BW Technologies) PID diffusion LCD w/ audio & visual alarms 

Phocheck 

(Ion Solutions) PID internal pump LCD 

Mini Rae 2000 

(Rae Systems) PID internal pump LCD w/ visual alarm 

Aeroqual 200 

(Aeroqual) semiconductor diffusion LCD 

Aeroqual 500 

(Aeroqual) semiconductor diffusion LCD w/ audio alarm 

C-21 

(Eco Sensors, Inc.) semiconductor diffusion LED bar w/ audible alarm 

D-Tek 

(Inficon) infrared cell internal pump audible w/ LED bar 

Tek-Mate 

(Inficon) semiconductor internal pump audible 

tif - 5100 

(tif Instruments) semiconductor diffusion audible 

Drager CMS 

(Drager) colometric internal pump LCD 

HW 101 reference analyzer 

(h⋅nu Systems) PID internal pump analog 

potentiometer 

Candidate analyzers were evaluated by exposing the analyzer probe a minimum of 

three times to both 25 ppmv and 50 ppmv PERC calibration standards contained in 

Tedlar bags. Gas was discharged by slowly depressing the bags by hand, no metering 

devices were used to control the rate of discharge. The stable response registered by 

each analyzer was recorded along with an approximation of the time necessary to attain 

the response. Standards were derived immediately prior to analyzer evaluation by 

transferring 25 ppmv and 50 ppmv PERC calibration standards directly into dedicated 3 

liter Tedlar bags from certified, traceable cylinders. The PERC concentration in each 

bag was then determined using the HW-101. 
H-3

Results for the portable VOC analyzer evaluations are reported in Table 2. The results 

include PERC standard concentrations, the number of exposures to each standard, the 

average response for each analyzer, and the average response time. Please note that 

the response times reported in Table 2 are the approximate time needed for the 

analyzer to display a stable concentration. Therefore, these values are inflated 

compared to the traditional definition of response time as the time required for the 

analyzer to register 50% (T50) or 90% (T90) of the standard concentration. 

The results indicate that portable PID analyzers with internal sample pumps (PhoCheck, 

MiniRae 2000) provide the best combination of accuracy and response time. Since PID 

analyzers are calibrated to isobutylene, its response to a PERC standard must be 

multiplied by a correction factor to obtain an equivalent response as PERC. The 

correction factor applied to PID analyzers in this survey is defined as the photoionization 

sensitivity ratio of PERC (8.6 eV) to isobutylene (5.5 eV) or 1.56. 

The Micro 5 diffusive PID analyzer also registered concentrations consistent with the 

calibration gas standards, though its response time was slightly longer than analyzers 

with an integral pump. The Micro 5 was evaluated versus the calibration gases using a 

manufacturer supplied faceplate which channels calibration gases directly to the 

detector. The faceplate is removed from the analyzer during field use. Since diffusive 

analyzers lack an integral sample pump, gas must be discharged from the Tedlar bag to 

the sensor by depressing the bag. Therefore, the time necessary for a diffusive 

analyzer to attain a stable response can be influenced by the rate of discharge from the 

bag, meaning response time can be affected by the magnitude of a leak. 

A variety of results were observed for diffusive analyzers incorporating semiconductor 

sensors. Analyzers producing an audible response, such as the tif – 5100 and Inficon 

Tek – Mate, demonstrated the ability to quickly detect the PERC standard. However, 

there is no discernible correlation between standard concentration and the audible 

frequency produced by these instruments. The tif – 5100 can also be induced into 

registering a positive response by blowing air across its sensor. 

The Aeroqual Series 200 and Series 500 analyzers were initially evaluated with the 25 

ppmv and 50 ppmv PERC standards August 12, 2005. At that time, the response from 

both analyzers to the calibration gases was a negative shift from the baseline 

concentration towards zero. Subsequent conversations with Aeroqual staff revealed 

that Aeroqual PERC analyzers are designed for optimum performance when the sample 

gas is between 30% and 80% relative humidity (RH). For calibration, or sample gases 

below 30% RH, the magnitude of negative shift increases with decreasing RH. The 

calibration gases used by STS are dry (0% RH), explaining the initial results. The 

Series 500 also displayed baseline concentrations of 7 ppmv to 11 ppmv, compared to 

the zero to 2 ppmv baseline concentrations registered by other analyzers. Replacing 

the Series 500 sensor head resulted in acceptable baseline concentrations. 
H-4

The Aeroqual Series 200 and Series 500 evaluations were repeated with humidified gas 

standards on August 23, and August 25, 2005. PERC standards were humidified to 

approximately 50% RH by injecting 30 microliters of distilled water into the 3 liter Tedlar 

bag and allowing the contents to equilibrate for 3 hours at 72 degrees Fahrenheit. 

Analysis of the humidified standards using the HW-101 indicates the humidifying 

process reduces the standard concentration by approximately one-third. 

Exposing the Aeroqual analyzers to the humidified standards produced a LCD response 

consistent with the concentration determined using the HW-101. However, there is 

increased potential for these analyzers to produce biased results when sample gas 

relative humidity is outside the range of 30% to 80%. Both the series 200 and Series 

500 demonstrated response times in the range of 20 to 30 seconds, which is 

significantly longer than the other diffusion analyzers. 

The Drager Chip Measurement System (CMS) uses an internal pump to draw sample 

through a gas-specific, reagent filled, capillary chip. The response times demonstrated 

by this analyzer (>100 sec.) indicate it is better suited for occupational safety 

applications rather than leak detection. This analyzer appears to be especially sensitive 

to sample pump inlet pressure and power supply (battery) voltage. Therefore, we are 

unsure if the poor results (29.6 ppmv) reported by the CMS for the 50 ppmv PERC 

standard represent typical instrument performance. 

The Eco Sensors C-21 and Inficon D – Tek analyzers did not produce any noticeable 

response to the PERC calibration standards. The lack of response by the D – Tek is 

understandable since its sensor is tuned to detect refrigerant compounds. The 

performance of the C-21 is confusing since a PERC calibration chart is supplied with the 

instrument and placing a felt tip marker near the C-21 sensor produces a full scale (140 

ppmv) response on the LED display. We believe the C-21 may also require a 

humidified gas sample to achieve a representative response. However, we are not 

currently in possession of a C-21 to test this theory and attempts by EES to obtain a 

replacement have, to this date, been unsuccessful. 

We hope the results presented in this memorandum are of assistance to the PERC 

ATCM amendment process. Please direct questions regarding the portable analyzer 

evaluation results to Angus MacPherson at 445-4686 or amacpher@arb.ca.gov. 
H-5

Table 2 

Portable VOC Analyzer Response to 25 ppmv and 50 ppmv PERC Calibration Gas St

Date Analyzer (display, detection, delivery) PERC standard conc. # Trials Average Response as PERC Response Time (sec) 

(see 

28 Jan 05 50 ppmv 4 31 Jan 05 

tif – 5100 (audible, semi 

conductor, diffusion) 25 ppmv 3 rapid beep < 5 be

influen

28 Jan 05 50 ppmv 4 31 Jan 05 

Eco Sensors C-21 (LED, 

semiconductor, diffusion) 25 ppmv 3 

no 

response 

na respo

requ

50 ppmv 3 49.5 ppmv < 5 23 May 05 PhoCheck (LCD,PID, internal pump) 25 ppmv 3 26.8 ppmv < 5 50 ppmv 3 constant tone < 5 23 May 05 Tek-Mate (audible, semi conductor, diffusion) 25 ppmv 3 constant tone < 5 cons

both 

50 ppmv 3 23 May 05 D-Tek (audible/LED, infrared, diffusion) 25 ppmv 3 no response na primar

refri

50 ppmv 3 58.0 ppmv 5 – 10 10 Aug 05 Micro 5 (LCD,PID, diffusion) 25 ppmv 3 26.4 ppmv 5 – 10 gas f

affe

50 ppmv 4 29.6 ppmv 110 10 Aug 05 Drager (LCD, chem. cell internal pump) 25 ppmv 3 20.7 ppmv 110 excess

results 

32 ppmv 2 30 ppmv 20 – 30 23 Aug 05 Aeroqual 200 (LCD, semi conductor, diffusion) 16 ppmv 2 15 ppmv 20 – 30 

25 Aug 05 Aeroqual 500 (LCD, semi conductor, diffusion) 36 ppmv 1 31 ppmv 20 – 30 

analysamp

50 ppmv 3 50.7 < 5 06 Sep 05 MiniRae2000 (LCD, PID internal pump) 25 ppmv 3 24.2 < 5 50 ppmv 8 48 ppmv < 5 All Dates HW – 101 (analog, PID, internal pump) 25 ppmv 8 26 ppmv < 5 r
Appendix I 

Contact Information for Alternative Solvents 
I-1

Contact Information for Alternative Solvents 

Solvent Company Address City State ZipCode 

DF-2000 ExxonMobil Chemical Co. 13501 Katy Freeway Houston TX 77079 (2PureDry 3M Global Headquarters 3M Corporate 

Headquarters, 3M Center 

St. Paul MN 55144 (8

EcoSolv Chevron Phillips 

Chemical Company, LLC 

10001 6 Pine Drive Woodlands TX 77380 (8

Shell Sol 140 HT Shell Chemical LP 7594 Highway 75 Geismar LA 70734 (2GreenEarth(D5) Dow Corning Corporation 2200 W. Salzburg Road Midland MI 48686 (9Rynex Rynex Cleaning Solutions 7600 Jericho Turnpike Woodbury NY 11787 (5Stoddard Qualitek International 315 Fairbank Street Addison IL 60101 (6Resolve R. R. Street & Co. Inc. 184 Shuman Blvd. Naperville IL 60563 (8Impress Lyondell Chemical Co. 1221 Mckinney St., One 

Houston Center, Suite 100 

Houston TX 77252 (7

Hydroclene Caled Chemical 26 Hanes Drive Wayne NJ 07470 (8
Appendix J 

Electricity Cost Calculations
J-1 

Electricity Cost Calculation 

Equation 1 was used in combination with the information provided to us 

from the Machine Manufacturer Survey to calculate maximum operating load in 

kW for each machine. 

(1) Maximum = (V)(A)(Power Factor)(Square Root of Phase)/1000 

Operating 

Load 

Where: 

V = machine voltage 

A = amperage of machine 

Power = power factor in percent, usually about 0.8 for single phase 

 Factor and 0.9 for three phase. 

Assuming a typical load draws a 30 percent average of the maximum 

operating load then Equation 2 was used to determine the kW that a typical load 

would draw. (JE, 2003) 

(2) Typical Load kW = (Maximum Operating Load)(30 percent) 

To calculate the hours that the machine runs Equation 3 was used. 

(3) Hours Ran = (cycles/day)(minutes/cycle)(60 minutes/hour) 

 Where: 

 Hours Ran = the hours that the machine runs for one day 

 Cycles/day = 6 cycles per day for a typical dry cleaner 

 Minutes/ = the time each machine takes to run one cycle 

 cycle 

Equation 4 was used to determine what the cost per day would be to run 

the dry cleaning machine. 

(4) Cost Per Day = (typical load)(hours ran)(cost per kW)

Where: 

Typical = kilowatts that a typical load draws, see Equation (2). 

 Load 

Hours ran = the hours ran, see Equation (3). 

Cost per = the current cost for kWh, which is $0.10. 

 kW 

 Typically a facility will dry clean 5 days a week. Equation 5 was used to 

determine the annual electricity cost for a facility to run their machine. 

(4) Cost Per Year = (cost per day)(5 days/week)(52 weeks/year)
Appendix K 

Summary of Comments
K-1 

Comments on California Dry Cleaning Industry 

Technical Assessment, October 2005 

GreenEarth Cleaning, November 22, 2005 

1. Page 11-3, Section II.C: Under Volatile Methyl Siloxane Cleaning, there is a 

statement, "GreenEarth Cleaning, who distributes the solvent." 

Comments: Please note that GreenEarth Cleaning does not distribute any 

solvent, machine or chemicals. We license the use of the patented process. The 

solvent is distributed by three approved silicone manufacturers, Dow Coming, 

General Electric and Shin-Etsu. 

2. Page VI-4, Section VI.D.: "However, all dry cleaning processes can result in soil 

contamination. Soil contamination can occur through accidental releases, such 

as spills, or during the distillation process from a boil-over."

Comments: Scientific studies on D5 have established that it cannot contaminate 

the soil. Using these studies as reference, the Silicones Environmental, Health 

and Safety Council (SEHSC) has concluded the following about D5: "In the soil, 

degradation and volatilization occurs within a week. D5 ultimately degrades to 

inorganic silicate, or sand, water, and carbon dioxide." 

3. Page VI-3, Section VI.C.: "The change in the amount of waste generated from 

solvent-based technologies (i.e., hydrocarbon, GreenEarth and Rynex) is 

relatively small compared to perc." 

Comments: The above statement is attributed to a report done by Jacobs 

Engineering, which did not include site visits or interviews with dry cleaners. 

Their conclusion in Section 5.2.8 of their report is not attributed to any actual 

supporting documentation and appears to be merely an assumption. 

Dry cleaners using the GreenEarth process in various types of machine 

configurations, with and without stills, report a significant decrease in the amount 

of waste generated versus perc or hydrocarbon. We have attached letters from 

current Affiliates documenting their actual experience. 

GreenEarth Cleaning would welcome an opportunity to work with the California 

Air Resources Board to develop actual volume waste data comparisons to perc 

and hydrocarbon in a format that would be acceptable for purposes of this report. 

4. Page VII-1, Table VII- I and Page VII-3, Table VII-2: In Table VII-1, the price 

range for machines using GreenEarth range from $43,000 to $98,000, while the 

price range for machines using hydrocarbon is $36,000 to $98,000. Then, using 
K-2 

an average machine price range for each, Table VII-2 shows that a machine 

using GreenEarth Cleaning costs $2,000 more than one using hydrocarbon. 

Comments: We understand that this information came from the Machine 

Manufacturer Survey. However, in reality a dry cleaner cannot purchase a 

machine that uses only hydrocarbon that is less expensive than a machine that 

will use either hydrocarbon or GreenEarth. We are not sure about the source of 

the price ranges, but we do not believe that they reflect reality. To support this, 

we have attached a letter from Jim Carroll, National Sales Manager of Union Dry 

Cleaning Products, one of the largest dry cleaning machine manufacturers in the 

world. 

5. Page VII-5, Table VII-4: Therm usage is taken from a study by PPERC, with 

GreenEarth data obtained from Cleaner By Nature in Los Angeles. 

Comments:

• The study by PPERC includes finishing, which makes the data collection 

much more subjective and less reflective of the actual cleaning process itself. 

Such factors as experience of the finisher, relative quality of the finished 

product, and other individual factors do not allow for an "apples-to-apples" 

comparison of gas usage of the various cleaning solvents. 

• The therm usage for GreenEarth reflected in this one study is not 

representative of reports from actual GreenEarth Affiliates. 

6. Page VII-6, Table VII-5: The annual operating cost for GreenEarth Cleaning is 

reported as higher than actual operating costs reported by GreenEarth dry 

cleaners due to (a) machine cost, (b) therm usage, and (c) maintenance cost. 

Comments: Machine cost is addressed in Item 3 above and therm usage is 

addressed in Item 4 above. Maintenance costs for GreenEarth are shown at 

$850 versus $250 for hydrocarbon. This is puzzling since the machines used 

and the recommended maintenance schedules are virtually identical for both 

solvents. This information apparently came from the Machine Manufacturer 

Survey, and the actual reports are not included in this draft for our review. 

Therefore, we are unable to address the reasons for this discrepancy. However, 

we have attached a letter from a major dry cleaning machine manufacturer that 

confirms that the cost of maintenance should be the same for GreenEarth and 

hydrocarbon. 

7. Appendix 1, Contact Information for Alternative Solvents: Dow Coming is listed 

as the contact for GreenEarth Cleaning. 

Comments: In addition to Dow Coming, there are two other approved suppliers 

of D5, the GreenEarth Cleaning Solvent. Contact information for the other two is: 
K-3 

• General Electric Advanced Materials, 187 Danbury Rd., Wilton, CT 06897. 

• Shin-Etsu Chemical, 115 0 Damar Dr., Akron, OH 44035. 

Silicones Environmental Health and Safety Council of North America (SEHSC) 

November 23, 2005 

1. In its report, the ARB has acknowledged the extensive health research submitted 

by the silicones industry in June 2005 to ARB, other California regulatory 

agencies, and U.S. EPA. However, we are concerned that by failing to 

specifically include or discuss the results of the additional research, the Draft 

Report fails to accurately and completely portray the current state of the 

knowledge regarding the safety of D5. Because the additional research 

specifically addresses the uncertainties that are mentioned in the Draft Report 

and further documents the safety of D5, it would be inappropriate for ARB to 

retain and rely on the information in Appendix G pertaining to cyclic siloxanes. 

SEHSC urges ARB to either update the Draft Report to reflect the current state of 

the knowledge regarding the safety of D5, or remove from Appendix G any 

information that pertains to D5 and, correspondingly, any reference to such 

information in Draft Report. Readers will be given an incomplete and inaccurate 

picture of the safety of D5 if the Draft Report is left as currently written. A 

summary of those studies in included in the comments. 

2. SEHSC recommends that the Draft Report be based on information currently 

available to ARB and OEHHA. SEHSC also recommends that OEHHA be given 

an opportunity to update the OEHHA memo under Appendix G as it has been 

superseded by subsequent research. This is particularly important as the 

additional research addresses ARB’s and OEHHA’s concerns. A majority of 

SEHSC’s specific comments address how the post-2003 research will change 

the conclusions of the December 2003 OEHHA evaluation. 

3. SEHSC would like to call to the attention of ARB that D5 is a nonsmog-forming 

material, which is a requirement for any alternative dry cleaning technology under 

California Assembly Bill 998. D5 has been classified as VOC exempt and is not 

listed as a hazardous air pollutant by the State of California. 

4. Section V.B.2. Page V-4. Potential Health Impacts—Volatile Methyl Siloxanes; 

The Draft Report states “The observance of adverse effects on the uterus by D5 

[in the D5 two-year study] is of concern (OEHHA 2003).” Mode-of-action 

research submitted to U.S. EPA and California regulatory agencies by SEHSC in 

June 2005 indicates that the uterine findings are specific to the rat and do not 

represent a hazard to humans. 

5. Section V.B.2. Page V-4. Potential Health Impacts—Volatile Methyl Siloxanes; 

The Draft Report states: “Because D5 is lipophilic there is also concern that D5 

may bioaccumulate in the food chain.” The silicones industry has conducted 
K-4 

extensive adsorption, metabolism, and excretion studies with D5 (Reddy et al. In 

Progress, Smith 2005, Plotzke 2001, Plotzke In Progress). These studies clearly 

show that D5 does not bioaccumulate in the food chain as research has shown 

that it does not bioaccumulate in mammals (Andersen et al. 2005). 

6. Section V.B.2. Page V-4. Potential Health Impacts—Volatile Methyl Siloxanes; 

The Draft Report notes a liver weight increase in a subchronic study with D5. 

Additional research on this effect, including chronic studies, show that this effect 

of D5 in rat liver is an indication of a non-adverse metabolic adaptation, not a 

toxic effect. 

7. Table V-2. Page V-8. Summary of Interim Health Values: The State of California 

has an established procedure for calculating a chronic REL from subchronic 

data. The chronic REL established for D5 by OEHHA was based on a 

subchronic study and used liver weight increase as the endpoint. Because the 

liver weight increase is related to D5’s phenobarbital-like activity, it has little or no 

relevance to humans (Whysner et al. 1996, Roberts et al. 1976, Parkinson 1995, 

Diwan et al. 1986, Olsen et al. 1989). In addition, a chronic study has been 

completed with D5, and this study should be used preferentially over the 90-day 

study. Therefore, to do a risk characterization or risk assessment and to assign 

a chronic REL for phenobarbital-like compounds based solely on liver 

enlargement in rodents is not appropriate, especially from a 90-day subchronic 

study. Furthermore, there is reference in the OEHAA toxicity data review that the 

chronic REL also was based on spleen changes in the subchronic study of 

Burns-Naas et al. There were no effects seen on the spleen in this subchronic 

study. 

We believe it would be inappropriate for OEHHA to set any exposure limits until 

the D5 two-year, combined chronic/carcinogenicity study and accompanying 

mode-of-action work provided in June 2005 are thoroughly assessed by the State 

of California. Using this approach would allow for a complete evaluation of all of 

the hazard data available on D5 and, if needed, would allow for the setting of an 

exposure limit based on sound scientific data. 

8. Section VI.A. Page VI-2. Groundwater Contamination: The Draft Report states 

“Based on preliminary findings from a study conducted by [SEHSC], the 

GreenEarth solvent is unlikely to leach into groundwater because it is not soluble 

and readily sticks to soil particles (GreenEarth 2003).” It should be noted that 

GreenEarth 2003 actually states “Based on conclusive test data with other 

silicone materials, if spilled on the ground, D5 is expected to decompose to 

carbon dioxide, silicon dioxide (sand), and water.” SEHSC does not have a 

study specifically looking at the ability of D5 to leach into groundwater. However, 

D5 has very low water solubility and will readily evaporate from water or bind to 

particles in water. In addition, if D5 is released to soil, it will readily evaporate 

(within ~2 days) from moist soil and will undergo degradation (within one week) in 

dry soil; ultimately degrading to inorganic silicate (sand), water, and carbon 

dioxide (Xu and Chandra 1999). In the atmosphere, the majority of D5 will 
K-5 

breakdown within 10 days (half-life of 7-10 days) (Atkinson 1991). Therefore, D5 

is unlikely to leach into groundwater. 

9. Section VI.D. Page VI-4. Environmental Impacts—Soil: The Draft Report notes 

all dry cleaning processes can result in soil contamination through accidental 

spills or releases. ARB should be aware that any D5 accidentally released to the 

environment in a spill will readily evaporate or undergo degradation in soil (Xu 

and Chandra 1999). When D5 enters the atmosphere, it undergoes degradation 

and is ultimately converted to inorganic silicate (sand), water, and carbon 

dioxide. In the atmosphere, a majority of D5 will break down within 10 days 

(half-life of 7-10 days) (Atkinson 1991). 

10. Table VI-3. Page VI-7. Potential Health Impacts and Permissible Exposure Limit 

(PEL): Table VI-3 indicates that D5 causes an increase in liver weight. This 

reported liver effect is an indication of metabolic adaptation in the rat and is not 

an indication of toxicity. This finding is widely recognized as not relevant to 

humans, and would be an inappropriate endpoint for the development of a 

Permissible Exposure Level (PEL). 

11. Appendix G provides an outdated and therefore inappropriate toxicological 

assessment of D5 and should be replaced with an updated review. 

12. Appendix G - Health effects of D4 (Octamethylcyclotetrasiloxane) in animals: 

SEHSC recommends that ARB remove the discussion of D4 from Appendix G, 

as D4 is not used as a dry cleaning solvent. Should these irrelevant references 

to D4 be retained, they should be amended to reflect the comments previously 

submitted by SEHSC (SEHSC 2004). These comments will not be repeated 

here. 

13. Appendix G - Chemical and Physical Properties: D5 is not listed as a hazardous 

air pollutant (HAP). D5 is considered VOC exempt by the U.S. EPA and by all 50 

states as well as by most of the air districts within the State of California.

14. Appendix G - Health effects information on D5 in the peer-reviewed literature: 

D5 does not have estrogenic or anti-estrogenic activity. Reference to the work of 

Hayden and Barlow (1972) is not appropriate. The cyclic phenyl-containing 

siloxanes assessed by Hayden and Barlow are not structurally analogous to D5. 

D5 does not have estrogenic or anti-estrogenic activity. There were no effects 

seen in the D5 two-generation reproductive study (WIL Research 1999). D5 was 

negative in the rat and mouse uterotrophic assay (Quinn et al. 2004, He et al. 

2003) and it does not bind to the estrogen receptor (Quinn 2004). Furthermore, 

data indicate that D5 does not cause estrogen receptor activation using the 

MCF-7 cell line (Quinn 2005). 

15. Appendix G - Health effects information on D5 in the peer-reviewed literature: 

Liver Effects in Rats. As for the liver effects seen with D5, it has been well 
K-6 

known since the early 1990s that exposure of some, but not all, experimental 

animal species to D5 produces hepatomegaly. 

16. Appendix G - Health effects information on D5 in the peer-reviewed literature: 

D5 does not bioaccumulate in mammalian species and therefore would not 

magnify. Examination of the work by Kala et al. (1998) reveals that authors did 

not conduct a mass balance determination of D5 and were unfamiliar with 

sample preparation and analytical techniques for siloxanes. As a result, the data 

reported by these authors in this paper are misleading. 

17. Appendix G - Health effects information on D5 in the peer-reviewed literature: 

D5 is non-genotoxic. Studies conducted with D5 include Salmonella typhimurium 

and Escherichia coli reverse mutation assays, an in vitro chromosome aberration 

test, and a combined in vivo rat micronucleus and UDS Assay (OECD 474, 

OECD 486). All of these studies on D5 were negative for genotoxicity activity 

(Sokolowski 2003, Schultz 2003, Honavar 2004). 

18. Appendix G - Health effects information on D5 in the peer-reviewed literature: 

Uterine Tumors in Rats. As noted above, the increased incidence of uterine 

tumors was not accompanied by an increase in incidence or severity of uterine 

endometrial hyperplasia. Post- 2003 mode-of-action studies have shown that D5 

acts as a dopamine agonist causing a reduction in prolactin. This reduction in 

prolactin causes a reduction in the estrogen:progesterone ratio leading to 

estrogen dominance. This effect is considered ratspecific since this pathway 

does not occur in humans (SEHSC et al. 2005). 

19. Appendix G - Interim inhalation chronic Reference Exposure Level (REL): 

SEHSC recommends that ARB remove the discussion of D4 from Appendix G, 

as D4 is not used as a dry cleaning solvent. In any future review of data on D4 

or D5, SEHSC requests that the State of California keep the data reviews on D4 

and D5 separate. Although these two materials are structurally similar (D4 has 

four Si-O units and D5 has five Si-O units), they have very different biological 

activities and different hazard profiles. Consideration of the two materials 

together may lead to false conclusions. 

20. Appendix G - Interim inhalation chronic Reference Exposure Level (REL): The 

State of California has an established procedure for calculating a chronic REL 

from subchronic data. The chronic REL established for D5 by OEHHA was 

based on a subchronic study and used liver weight increase as the endpoint. 

Because the liver weight increase is related to D5’s phenobarbital-like activity, it 

has little or no relevance to humans (Whysner et al. 1996, Roberts et al. 1976, 

Parkinson 1995, Diwan et al. 1986, Olsen et al. 1989). In addition, a chronic 

study has been completed with D5, and this study should be used preferentially 

over the 90-day study. Therefore, to do a risk characterization or risk 

assessment and to assign a chronic REL for phenobarbital-like compounds 

based solely on liver enlargement in rodents is not appropriate, especially from a 
K-7 

90-day subchronic study. Furthermore, there is reference in the OEHAA toxicity 

data review that the chronic REL also was based on spleen changes in the 

subchronic study of Burns-Naas et al. There were no effects seen on the spleen 

in this subchronic study. 

We believe it would be inappropriate for OEHHA to set any exposure limits until 

the D5 two-year, combined chronic/carcinogenicity study and accompanying 

mode-of-action work provided in June 2005 are thoroughly assessed by the State 

of California. Using this approach would allow for a complete evaluation of all of 

the hazard data available on D5 and, if needed, would allow for the setting of an 

exposure limit based on sound scientific data. 

Lyondell Chemical Company, November 22, 2005 

1. Lyondell Chemical Company is the manufacturer of ImpressTM solvent for dry 

cleaning. Impress solvent is a proprietary composition containing prdominantly 

dipropylene glycol n-propyl ether (DPnP). Lyondell is providing additional 

information on mammalian toxicity and ecological studies done on DPnP. 

Because Impress solvent is predominantly DPnP, the toxicity of IMPRESS dry 

cleaning solvent is expected to be very similar to the DPnP. 

Chevron Phillips Chemical Company LP, November 22, 2005 

1. II-B-3, Page II-2: Advise to replace this paragraph with the following: Chevron 

Phillips Chemical Company LP manufactures EcoSolv® Fluid (EcoSolv). This 

dry cleaning fluid is predominantly a mixture of synthetic isoparaffins with carbon 

numbers ranging from C9 to C13. The manufacturer formulated this product by 

adding butylated hydroxytoluene at 10 parts per million (ppm) to act as an 

oxygen stabilizer. This solvent is a high purity aliphatic mixture very low in 

aromatics. EcoSolv® fluid has been approved by the New York State Department 

of Environmental Conservation as a solvent meeting their HAP requirements. 

Isoparaffin solvents are also used for food processing, cosmetic and personal 

care formulations, and as solvents for a number of industrial products. EcoSolv 

has a flash point between 140 o

F and 200 oF, and is classified as Class IIIA 

solvent per NFPA 32. (ARB, 2004h) 

2. IV-A-3, Page IV-5: The text states that the group was not aware of any cleaners 

using EcoSolv® fluid in California. Chevron Phillips currently has approximately 

50% of the market in Northern California and 30-40% of the market in Southern 

California.

3. Section V-B-1, Page V-3: The Report states that the environmental persistence 

of EcoSolv® DCF is not known. The environmental fate of our product has been 

evaluated and data submitted to the OECD SIDS HPV Initiative with US EPA as 

Sponsor. Biodegradation data available show that C10-C13 isoparaffinic 

hydrocarbons can exhibit a moderate to rapid rate of biodegradation. In a Ready 
K-8 

Biodegradability test, a C10-C13 aliphatic compound showed a 69.8% 

biodegradation in 28 days. 

4. For trademark protection purposes, we would like our product to be referred to as 

EcoSolv® Dry Cleaning Fluid or EcoSolv® DCF through out the report. 

5. There are two predominant products/manufacturers of synthetic or isoparaffinic 

hydrocarbon solvents; they are DF-2000 from Exxon and EcoSolv® DCF from 

Chevron Phillips. We recommend modifying the generic references to DF-2000 

to synthetic/Isoparaffinic solvents which include both DF-2000 and EcoSolv® 

DCF. 

6. The page numbers in section I might have been numbered wrongly. They should 

read I-1, I-2, I-3, etc.

Bill Hayday (Rynex), November 15, 2005 

1. All of the solvents listed excluding Perc are both flammable and combustible. 

Rynex should not be listed as hazardous because it’s combustible since they are 

all combustible. Please change this and also remove the carcinogenic reference 

since Rynex is non-carcinogenic. Petroleum’s and silicones cannot make this 

claim. 

ExxonMobil Chemical Company, November 29, 2005 

1. Page II-2: Include Flash point for DF-2000 Fluid of 144 oF. 

2. Page IV-7: The REL for DF-2000 Fluid is 171 ppm or 1200 mg/m3 with footnote 

to reference published method JOEH 2005. 

3. December 2003 memo from Alexeeff to OEHHA needs to be revised/updated to 

reflect current data on DF-2000 fluid. Are the units on the REL correct? 

4. Pure-Dry-4 references the Phillips and Egan study (1984). Please note that the 

effects were related to male rat kidney effects that U.S. EPA has determined to 

be species/sex specific. Is it appropriate to use this study? 

5. Page V-3, 5th paragraph: DF-2000 Fluid contains C11-C13 synthetic isoparaffin 

aliphatic hydrocarbons. 

6. Page V-4, 1st sentence: Check the last word in the first sentence of the page; 

should be rats and not rates? 

Aeroqual Limited, November 18, 2005 

1. Aeroqual has provided for testing their new perchloroethylene leak detector 

sensor head with Aeroqual Series 200 handheld monitor. After testing they 

would like ARB to add the test results to the final ATCM report. 
K-9 

2. Table IV-16, Summary of Leak Detector Evaluation: After testing the new leak 

detector please add the following information to Table IV-16: 

Model and Manufacturer: Aeroqual 200 Leak Detector

Detection Principle: Gas sensitive semiconductor 

Sample Delivery: Internal fan 

Display: LCD with audible alarms 

Response Time: < 5 seconds 

Leak Check Suitability: Yes 

3. There will be no change to Table VII-6. Comparison of Cost for Perc 

Concentration Detectors because the cost of the Aeroqual Series 200 Leak 

Detector is the same as the standard Series 200 handheld monitor ($580). 

ION Science, October 21, 2005 

1. Table IV-16: The PhoCheck 1000 (ION Solutions) should actually read 

PhoCheck 1000 (ION Science). 

2. Table VII-6: The cost of the PhoCheck 1000 should be changed from $2,745 to 

$1,999. 

Turlock Dry Cleaning, November 19, 2005 

1. I am the owner of Turlock Dry Cleaning in Turlock, CA. I personally like the 

strength and effectiveness of Perc and am willing to stick with it. No other 

product that I have tried has compared to perc, and changing it will cause a 

considerable drop in the quality of my dry cleaning. If anything else is required of 

me please inform me via email. 

HSIA, November 22, 2005 

1. Page I-2, 2nd to last paragraph – In addition to noting that PERC emissions have 

decreased by about 70 percent, it would be helpful to note that the industry’s 

efficiency has more than doubled (lbs per gal increased from 224 in 1992 to 566 

in 2003). 

2. Page II-2, B. Hydrocarbon Solvent Cleaning – To avoid confusion and improve 

clarity, the discussion of Hydroclene Fluids (page II-6) can be included in the 

Hydrocarbon section. These fluids are similar to the other hydrocarbons 

discussed in this section, and already are available to the industry. 

3. Page II-3, D. Rynex Cleaning – This section should be retitled “Propylene Glycol 

Ether Solvent Cleaning” and the discussion of Impress Solvent (page II-6) should 

be included. Both Impress and Rynex are P-series glycol ethers and have 

similar properties. Impress also is already available to the industry. 
K-10 

4. Page V-1, 1st paragraph – The fourth sentence of the paragraph should be 

rephrased to read “Many of the human studies have been conducted among 

populations of dry cleaning workers.” The current language suggests that 

toxicological studies were conducted on the workers. 

Bob Blackburn, November 1, 2005 

1. Page II-3(D) – RynexTM (Propylene Glycol Ether) Cleaning. Suggest changing 

the language in the first paragraph, 4th statement, to “It is considered to be nonhazardous under OSHA Hazardous Communication Standards because it is a 

non-combustible liquid. It is also considered a non-regulated VOC because of its 

low volatility rating.” 

2. Page V-4(3) RynexTM (Propylene Glycol Ether): Please remove the statement 

pertaining to no toxicity data on Rynex. 

3. Page V-5 (top of page): Either omit the entire paragraph and replace it with this 

one or add this one at the bottom of the one you have. This paragraph MUST be 

included for correct current information. 

“The current formulation of RynexTM is not regulated under California Prop 65, 

the Clean Air Act, the Clean Water Act, the Safe Drinking Water Act or as a 

hazardous air pollutant (HAP). It is noncarcinogenic, biodegradable and has low 

toxicity. It is also not classified as hazardous waste material. 

Most reporting and special paperwork is eliminated because RynexTM has not 

been designated as a hazardous chemical by the Federal EPA. RynexTM can be 

used in any hydrocarbon machine with minor modifications. Most manufacturers 

now offer RynexTM ready machines in capacities to meet every need. RynexTM 

has been field tested in California for 2 years and it has been determined that it 

has outstanding cleaning properties. It cleans as well or better than perc on a 

wider range of garment fabrics. RynexTM also removes more stains during 

normal cycling so that less pre- and post-spotting is required. It is safe for use on 

most beads, sequins, buttons, leather and trim.” 

4. Appendix G, Page PGtBE-1: At the top under the heading of PROPYLENE 

GLYCOL TERT-BUTYL ETHER must have this disclaimer, “The following report 

is based on a previous RynexTM formulation. 

Bob Blackburn, November 10, 2005 

1. Page VI-4: E. Flammability: Paragraph 3: (statement as it reads now) - RynexTM 

which has a flashpoint of greater than 200 degrees F is classified as a 3B liquid 

and a potential fire safety hazard. It SHOULD read: RynexTM which has a 

flashpoint of greater than 200 degrees F is classified as a 3B liquid and is not a 

potential fire safety hazard. 
K-11 

2. Page VII-6: Chart: Under RynexTM it now reads: Average cost for 

detergents/spotting agents $1500.00 per year. It should say: Average cost for 

detergents/spotting agents $100.00 (spotting agents only) no detergents used. 

3. Page VIII-2: B: Rynex - now reads: The Air Resources Board (ARB) staff was 

not able to locate any independent efficacy testing for RynexTM. However, the 

manufacturer claims that RynexTM is a superior, gentler cleaner (when compared 

to Perc) that can handle a wide variety of fabrics. They also claim that it removes 

water soluble stains better than other solvents (Ryenx, 2005), although this has 

not been verified with independent testing. 

It should read: The manufacturer claims that RynexTM is a superior, gentler 

cleaner (when compared to Perc) that can handle a wide variety of fabrics. They 

also claim that it removes water soluble stains better than other solvents, this has 

been verified with those cleaners using RynexTM as a true statement (Please 

delete the beginning and ending statements regarding the independent testing 

and unverified documentation). 
Appendix L 

Glossary and Acronyms
L-1

Glossary 

Acute Exposure: One or a series of short-term exposures generally lasting less 

than 24 hours. 

Agency Shop: Same as drop off shop. Facility with no dry cleaning machine 

on-site. 

Airborne Toxic Section 39655 of the Health and Safety Code, defines an 

Control Measure: “Airborne Toxic Control Measure” means either of the 

following: 

 1) Recommended methods, and, where appropriate, a range 

of methods, that reduce, avoid, or eliminate the emissions of a 

toxic air contaminant. Airborne toxic control measures 

include, but are not limited to, emission limitations, control 

technologies, the use of operational and maintenance 

conditions, closed system engineering, design equipment, or 

work practice standards, and the reduction, avoidance, or 

elimination of emissions through process changes, substitution 

of materials, or other modifications. 

 2) Emission standards adopted by the U.S. Environmental 

Protection Agency pursuant to section 112 of the federal act 

(42 U.S.C. Sec. 7412). 

Air Dispersion A mathematical model or computer simulation used to 

Model: estimate the concentration of toxic air pollutants at specific 

locations as a result of mixing in the atmosphere. 

Chronic Exposure: Long-term exposure usually lasting from one year to a lifetime. 

Drop off Shop: Same as agency shop. Facility with no dry cleaning machine 

on-site. 

Flash Point: The lowest temperature at which a liquid can form an ignitable 

mixture in air near the surface of the liquid. The lower the 

flash point, the easier it is to ignite the material. 

Hazardous Air A substance that the U.S. Environmental Protection 

Pollutant (HAP): Agency has listed in, or pursuant to, section 112 subsection 

(b) of the federal Clean Air Act Amendments of 1990 

(42 U.S. Code, section 7412(b)). 

Mixed Shop: A dry cleaning facility that employs more than one type of dry 

cleaning process. 
L-2

Permissible Exposure The maximum amount or concentration of a chemical that a 

Limit (PEL): worker may be exposed to under the Occupational Safety and 

Health Administration (OSHA) regulations. 

Risk: The possibility of injury or disease, which may result from 

 exposure to toxic air contaminants. 

 

Scientific Review A nine-member panel appointed to advise the Air Resources 

Panel on Toxic Air Board and the Department of Pesticide Regulation in their 

Contaminants (SRP): evaluation of the adverse health effects toxicity of substances 

being evaluated as Toxic Air Contaminants. 

TIF Detector Halogen leak detector made by TIFTM Instruments, Inc. 

Toxic Air Section 39655 of the Health and Safety Code, defines a TAC 

Contaminant (TAC): as an air pollutant which may cause or contribute to an 

increase in mortality or an increase in serious illness, or which 

may pose a present or potential hazard to human health. A 

substance that is listed as a hazardous air pollutant pursuant 

to subsection (b) of section 112 of the federal act 

(42 U.S.C. Sec. 7412(b)) is a TAC. TACs that are pesticides 

are regulated in their pesticidal use by the Department of 

Pesticide Regulation. 

Volatile Organic Means any compound containing at least one atom of carbon, 

Compound (VOC) excluding carbon monoxide, carbon dioxide, carbonic acid, 

metallic carbides or carbonates, and ammonium carbonate, 

and excluding the following: 

(A) methane, methylene chloride (dichloromethane), 

1,1,1-trichloroethane (methyl chloroform), 

trichlorofluoromethane (CFC-11), 

dichlorodifluoromethane (CFC-12), 

1,1,2-trichloro-1,2,2-trifluoroethane (CFC-13), 

1,2-dichloro-1,1,2,2-tetrafluoroethane (CFC-14), 

chloropentafluoroethane (CFC-115), 

chlorodifluoromethane (HCFC-22), 

1,1,1-trifluoro-2,2-dichloroethane (HCFC-123), 

1,1-dichloro-1-fluoroethane (HCFC-141b), 

1-chloro-1,1-difluoroethane (HCFC-142b), 

2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124), 

trifluoromethane (HFC-23), 1,1,2,2-tetrafluoroethane 

(HFC-134), 1,1,1,2-tetrafluoroethane (HFC-134a), 

pentafluoroethane (HFC-125), 1,1,1-trifluoroethane 

(HFC-143a), 1,1-difluoroethane (HFC-152a), cyclic, 
L-3

branched, or linear completely methylated siloxanes, the 

following classes of perfluorocarbons: 

1. cyclic, branched, or linear, completely fluorinated 

alkanes; 

2. cyclic, branched, or linear, completely fluorinated 

ethers with no unsaturations; 

3. cyclic, branched, or linear completely fluorinated 

tertiary amines with no unsaturations; and 

4. sulfur-containing perfluorocarbons with no 

unsaturations and with the sulfur bonds to carbon and 

fluorine, and 

(B) the following low-reactive organic compounds which have 

been exempted by the U.S. EPA: acetone, ethane, methyl 

acetate, parachlorobenzotrifluoride (1-chloro-4-trifluoromethyl 

benzene), perchloroethylene (tetrachloroethylene).

 
L-4

ACRONYMS 

APCD Air Pollution Control District 

APCO Air Pollution Control Officer 

AQMD Air Quality Management District 

ARB California Air Resources Board 

ATCM Airborne Toxic Control Measure 

BACT Best Available Control Technology 

Cal/EPA California Environmental Protection Agency 

Cal/OSHA California Occupational Safety and Health Administration 

CAPB Cocamidopropyl betaine 

CAPCOA California Air Pollution Control Officers Association 

CAS Chemical Abstract Service 

CG Cellulose gum 

CEQA California Environmental Quality Act 

CO2 Carbon Dioxide 

CTSI U.S. EPA’s Cleaner Technologies Substitute Assessment : 

Professional Fabricare Processes

 

D5 Decamethylcyclopentasiloxane 

DfE Design for the Environment 

DHS California Department of Health Services 

Districts Local Air Pollution Control and Air Quality Management Districts 

DOF California Department of Finance 

DPNB Dipropylene Glycol Normal Butyl Ether 

DTSC California Department of Toxics Substances Control 

°

F Degrees Fahrenheit 

HAP Hazardous Air Pollutant 

HHD Halogenated Hydrocarbon Detector 

H&SC Health and Safety Code 

HSIA Halogenated Solvent Industry Alliance 

IARC International Agency for Research on Cancer 

IFI International Fabricare Institute 

IRTA Institute for Research and Technical Assistance 

KB Kauri Butanol 

Kg Kilogram 

kWh Kilowatt-hour 

Lauramide DEA lauric acid diethanolamide 

LOC Local ventilation system 
L-5

m

3

 Cubic meter 

MDL Minimum Detection Limit 

μg/m3 Microgram per cubic meter 

MSDS Material Safety Data Sheets 

NESHAP National Emissions Standards for Hazardous Air Pollutants 

NIOSH National Institute for Occupational Safety and Health 

NTP National Toxicology Program 

OEHHA Office of Environmental Health Hazard Assessment 

OSHA Occupational Safety and Health Administration 

P-20 Ethoxylated sorbitan monodecanoate 

PBR Partial vapor barrier room 

PEL Permissible Exposure Limit 

Perc Perchloroethylene 

pH A logarithmic measure of hydrogen ion concentration 

PID Photoionization Detector 

POTW Publicly Owned Treatment Works 

PPERC Pollution Prevention Education and Research Center 

ppm Parts per Million 

ppmv Parts per Million by Volume 

psi Pound Per Square Inch 

PVR Partial Vapor Room 

REL Reference exposure level 

SEHSC Silicones Environmental, Health & Safety Council of North America 

SLI Sodium lauryl isethionate 

SLS Sodium laureth sulfate 

SRP Scientific Review Panel on Toxic Air Contaminants 

TAC Toxic Air Contaminant 

TLV Threshold Limit Value 

TSCA Toxic Substances Control Act of 1976 

TWA Time-weighted average 

UCLA University of California, Los Angeles 

URF Unit risk factor 

U.S. United States 

U.S. EPA United States Environmental Protection Agency 

VBR Vapor Barrier Room 

VOC Volatile Organic Compound