# 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 S ection Daniel E. Donohoue, Chief, Emissions Assessment Bra nch Robert D. Barham, Ph.D., Assistant Chief, Stationar y Source Division Robert D. Fletcher, Chief, Stationary Source Divisi on

February 2006

## ACKNOWLEDGMENTS

We wish to acknowledge the participation and assist ance of the following local air
districts.

Bay Area Air Quality Management District Mojave Desert Air Quality Management District Santa Barbara County Air Pollution Control Distric t 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 Or banosky Monitoring and Laboratory Division, ARB Angus Macp herson 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 Sins heimer GreenEarth ®

Cleaning James E. Douglas
ExxonMobil Chemical Arlean Medeiros Kelleher Equipment Supply, Inc. Kelly Kelleher C asares

### 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 (CO 2 ) Cleaning......................................... ...........II-4 F. Professional Wet Cleaning ....................... ....................................II-4 G. Green Jet ®

................................................... .................................II-5 H. Emerging Technologies........................... .....................................II-5 1. Cold Water Cleaning Syste ms ..............................................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 .................................................II I-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 .................................................. I V-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, Pur eDry, 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 Warmin g .............. 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 D etermination of

Tetrachloroethylene in Dry Cleaning Sludge by Gas Chromatography - FID

Appendix E: Standard Operating Procedure for the D etermination of
DF-2000 TM in Dry Cleaning Sludge by Gas Chromatograp hy – Mass Selective Detector

Appendix F: Sludge Sampling Results

### TABLE OF CONTENTS (continued)

APPENDICES (continued)

Appendix G: OEHHA Memorandum

Appendix H: Laboratory Evaluation of Leak Detector s

Appendix I: Contact Information for Alternative So lvents

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 Cleani ng Industry ......................I-3
Table IV-1 Business Information.................... .................................................. I V-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..................... .................................................. I V-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 Test s .............................. IV-19 Table IV-16 Summary of Leak Detector Evaluation .... ..................................... IV-21 Table IV-17 Facility Survey Summary for Emission An alysis........................... 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 Classificati on 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 D ry Cleaning Facility ...... VII-3 Table VII-3 Dry Cleaning Solvent Costs ............ .............................................. VII-4 Table VII-4 Average Machine Gas and Electricity Usa ge for Each Dry Cleaning Process............................. ....................................... VII-5 Table VII-5 Annual Cost Comparison for the First Fi ve Years of a Typical Size Dry Cleaning Facility....................... ....................................... VII-6 Table VII-6 Comparison of Cost for Perc Concentrati on Detectors.................. VII-7 Table VIII-1 Summary of KB and Surface Tension Valu es 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 ........ .................................................. I V-9 Figure IV-6 Map of Facility Site Visit Locations ... ............................................ IV-15I-1



### I. INTRODUCTION

A. Background

An assessment of dry cleaning technologies was perf ormed 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 (Pe rc) dry cleaning to the available alternatives and determine whether the Dry Cleaning ATCM, which was originally adopted in 1993, continues to be adequately protect ive of public health. The last technology assessment was conducted from 1991 to 19 93 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 resu lts to the earlier assessment.

Information regarding the California dry cleaning i ndustry 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 C alifornia Air Resources Board (ARB), in cooperation with the California Cleaners Association, the Korean Dry Cleaners-Laundry Association, other industry repres entatives, and the local air districts. The purpose of the survey was to collect informatio n from the dry cleaning facilities. The Machine Manufacturers Survey was used to collec t information about cost and other machine information. The Perc Solvent Distri butor’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 f acilities survey. Additionally, the Dry Cleaning Solvent Manufacturers Survey was used to obtain formulation information which was shared with the Office of Environmental H ealth Hazard Assessment (OEHHA). OEHHA used this information to provide in put to the ARB regarding the health effects and toxicity of the solvents that ar e discussed in this report.

ARB staff conducted site visits of dry cleaning fac ilities and conducted emissions testing to enhance our understanding of the Califor nia dry cleaning industry and the dry cleaning process. Staff visited over 100 facilitie s around the state collecting relevant information (e.g. distance to receptors, ventilatio n practices, and solvent usage). Our testing included collecting and testing sludge from Perc and DF-2000 TM Fluid (DF-2000) dry cleaning facilities, evaluating the effectivene ss of Perc detectors, and measuring Perc concentrations around Perc dry cleaning machin es and other locations in the
facilities.

B. Industry Characteristics

California dry cleaners are typically small busines ses 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. OtherI-2

common sources of income include laundry and altera tion. The industry is highly competitive; even though about half of the dry clea ners have been in operation for 10 years or more, around 30 percent have been in th e business for five years or less. Most facilities are open for business from Monday t hrough Saturday

There are about 5,040 dry cleaning facilities in th e state. Over 95 percent of these facilities operate a single dry cleaning mach ine and over 82 percent of the dry cleaning machines use Perc as the solvent. There a re 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). Ov er half of the machines in operation are primary machines and about a third of the machi nes 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 compare s these estimates with those made in the early 1990’s during the ATCM rule devel opment process.

Table I-1. Statewide Estimates of Perc Dry Cleanin g Operations

Statewide Estimates 1991 Survey 2003 Survey Number of Perc dry cleaning machines 1 5,310 4,670 Pounds of materials dry cleaned annually 2 258 million 256 million Pounds of materials dry cleaned using Perc annually 2 247 million 214 million

Gallons of Perc used 3 1,100,000 378,000

Gallons of Perc emitted 3 742,000 222,000

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 m achines currently in operation statewide. This is an estimated 12 perce nt decrease from 1991. In addition, the amount of clothes cleaned by Perc machines has correspondingly decreased by approximately 13 percent. An interesting observati on is that the amount of clothes dry cleaned annually has remained about the same. We b elieve 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 decreas ed by about 70 percent after implementation of the Dry Cleaning ATCM.

The types of alternative solvents used in 1991 incl uded: Stoddard Solvent (Stoddard), CFC-113, and 1,1,1-Trichloroethane. An d, as shown on Table I-1, about 96 percent of the clothes dry cleaned used Perc. Curr ently, 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 Exxon Mobil. Other alternative cleaning processes and cleaning solvents include: carbon di oxide (CO 2 ) cleaning, water-based cleaning systems such as professional wet cleaning (wet cleaning) and Green Jet I-3

(Green Jet), GreenEarth  (GreenEarth), Rynex TM (Rynex 3), PureDry  (PureDry), Stoddard, as well as other high flash point hydroca rbon 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 a nalysis of these technologies, as well as other available technologies is presented in Cha pter II.

Table I-2. Statewide Estimates - California Dry Cl eaning Industry 1

Statewide Estimates Number 2 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, Ryne x 3, Stoddard, and other high flash point hydrocarb on 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 emplo y a transfer process that requires moving the material being cleaned from a w asher to a dryer. The facilities that
use DF-2000 and other available alternatives normal ly 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 act ivated) and CO 2 machines, most of these closed-loop machines operate with primary con trol and usually with a water separator and vacuum still. It is reported that th e machines that operate with Tonsil  (Tonsil) can operate without a still (Kelleher, 200 4). Tonsil has been in use for the last few years and cleaners typically use it in a 50 per cent tonsil/ 50 percent diatomaceous earth blend (IRTA, 2005). Cost of alternative mach ines, with the exception of wet cleaning and Green Jet machines, are typically high er 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 ch apter also briefly discusses some emerging dry cleaning technologies which are not fu lly commercially developed in California.

A. Perchloroethylene Cleaning

Perchloroethylene (Perc) is the most widely used d ry cleaning solvent in California. Perc is also used in other industry se ctors including degreasing operations, paints and coatings, and industrial and consumer pr oducts. 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 o f 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 eithe r with primary controls (primary control machines) or with both primary and secondary controls (secondary control machines). Primary control machines featur e 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 reheat ed 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 featu res one or more carbon adsorber beds in addition to the refrigerated condenser. Th e carbon adsorber operates during the cool-down phase and can reduce the Perc concent ration to less than 300 parts per million by volume (ppmv). During regeneration of t he 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 co ncentration exceeds a set point (normally 300 ppmv), may also be installed.

B. Hydrocarbon Solvent Cleaning

All hydrocarbon solvents used in dry cleaning cons ist of aliphatic hydrocarbons, meaning they are straight-chained, branched or cycl ic as opposed to aromatics, which contains stable carbon-ring structures called benze ne rings. Hydrocarbon solvents are combustible. Inherent properties of petroleum-base d solvents include high flammabilityII-2

(more detailed discussion of flammability is presen ted 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 organ ic 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 ExxonMob il as an alternative solvent to Stoddard and Perc. Currentl y, it is the most popular alternative to Perc. Consisting of C 11 to C 13 aliphatic hydrocarbons, it is a synthetic mix of i soparaffins and cycloparaffins (naphthenes) that boils between 185 and 211 degrees Centigrade (OEHHA, 2003). Machines designed for DF-2000 and o ther 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 p roduced by 3M. The mixture contains about 95 percent odorless mineral spirits. The odorless mineral spirits are a mixture of aliphatic hydrocarbons (C 9 to C 12 ). Mineral spirits can cause neurotoxicity, and eye and respiratory irritation at high concentr ations. 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 (perflu oro compounds of primary seven carbons), and PF-5060 (perfluoro compounds of prima rily 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 vapo r 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 poi nts for all dry cleaning solvents range
from 110 ° F to 350 ° F.

3. EcoSolv 

Chevron Phillips Chemical Company LP manufactures E coSolv  (EcoSolv). This dry cleaning fluid is 100 percent isoparaffin with carbon numbers ranging from C 9 through C 13 . The manufacturer formulated this product by addi ng 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 pro cessing, 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 s olvents, consists of a blend of C 8 to C 12 hydrocarbons and is similar to kerosene. Its flas h point is 110 ° F. Stoddard
contains small amounts of chemicals known to be car cinogenic but are not classified as toxic. Stoddard also contains benzene, which has b een identified as a toxic air contaminant. It also gives off an irritating odor.

C. Volatile Methyl Siloxane Cleaning

Decamethylcyclopentasiloxane (D 5 ) or volatile methyl siloxane is an odorless, colorless liquid that has many consumer and industr ial applications. D 5 is used as an ingredient in a number of personal health and beaut y products, including deodorants, antiperspirants, cosmetics, shampoos, and body loti ons. It is also used as a dry cleaning solvent.

D 5 is present in the GreenEarth  (GreenEarth) dry cleaning solvent. GreenEarth solvent is mostly being used in hydrocarbon machine s 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 manufactu rer: filtration system; temperature control sensors; pre-water separator filter; water separator; and electrical control panel. GreenEarth solvent is distributed by Dow Corning, G eneral Electric, and Shin-Etsu.

D. Rynex  (Propylene Glycol Ether) Cleaning

Rynex  (Rynex 3) is an organic and biodegradable solvent w ith low volatility and a high flash point (>200 ° F) and is classified as a Class IIIB solvent. Ryne x 3 is lighter than water and, therefore, floats on water after se paration. It is a mixture of substituted aliphatic glycol ethers. It is also considered a V OC.

Rynex 3 can be used in most hydrocarbon machines wi th some temperature and timing adjustment. Converting Perc machines to use Rynex 3 is not recommended by
the solvent manufacturer. It is not an economicall y prudent exercise due to the differences in physical properties of Perc and Ryne x 3.II-4

E. Carbon Dioxide (CO 2 ) Cleaning

Carbon dioxide cleaning (CO 2 ) is a process that has been developed for use by commercial and retail dry cleaners. CO 2 is a non-flammable, non-toxic, colorless, tasteless, odorless naturally-occurring gas that, w hen subjected to pressure, becomes a liquid solvent. The liquid CO 2 cleaning machines have a configuration which is si milar to a solvent or Perc machine. The system is closed loop and comes equipped with a cleaning chamber, storage unit, filtration, distill ation, and lint trap. Washing, vapor recovery, and drying are all performed in the clean ing chamber.

The CO 2 machines pressurize the gas in a drum to between 7 00 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 CO 2 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 CO 2 is pulled out to prevent the dirt from being re-deposited on the clothing. At the end of the cy cle (35-40 minutes), the pressure is

released and the CO 2 returns to a gaseous state, with dirt and substanc es removed from the clothing (the dirt and debris end up in th e bottom of the tank). Cooling and drying of the clothes occurs as the liquid CO 2 evaporates.

The CO 2 used in this process is an industrial by-product fr om existing operations, primarily anhydrous ammonia (fertilizer) production . There is no net increase in the amount of CO 2 emitted; therefore, this process does not contribu te to global warming.

CO 2 is naturally occurring and is also used in other a pplications such as carbonating
soft drinks. There are three manufacturers of CO 2 equipment in the United States.

F. Professional Wet Cleaning

Professional Wet Cleaning (wet cleaning), an altern ative to dry cleaning that was first introduced in 1991, is different than commerc ial laundering in several aspects. Wet cleaning uses computer-controlled washers and dryer s with detergents that have been specially formulated for the process. Specialized equipment is used because ordinary washers and dryers lack the necessary control neede d to ensure that garments are processed properly. Finishing equipment includes p ressing 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 acceler ation and deceleration can be created. The wash program software can determine t he appropriate combination of time, water level, water temperature, extraction, a nd drum rotation when manual operation is not desired. Washers are also designe d to mix water with cleaning agents prior to entering the drum.II-5

Wet cleaned garments must be carefully dried in pre paration for finishing. Wet cleaning generally takes about 45 minutes from wash through drying, not including the finishing time. As with high drum agitation, prolo nged 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 humi dity level in the garments has been
achieved.

Wet cleaning systems use non-toxic, biodegradable d etergents, which are approved for disposal into the sewer system. The d etergents are designed to be pH neutral and incorporate agents which prevent the in terlocking of fibers. Many stains, such as salts, sugars, and foods and drinks, are re adily removed by the wet cleaning process. Wet cleaning can also clean oil-based sta ins with the use pre-spotting chemicals that are specifically designed for water- based cleaning. Wet cleaning systems may also be gentler on buttons and ornament al 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 remov e humidity and reduce surface tension, which allows mechanical action and pulsati ng air jets to dislodge and remove non-soluble soil from the garments. This soil is t hen collected in a lint chamber. Next, a pre-determined amount of water-based cleaning solut ion is injected through air jet nozzles to re-hydrate the fabric. After about a pi nt of solution has been injected, heavy felt pads attached to the ribs and the cylinder abs orb the soluble soil. After the cleaning process, the unit goes into a conventional dry cycl e and then a cool-down cycle.

H. Emerging Technologies

There are four emerging technologies which are exp ected to be readily available to the dry cleaning industry within the next few ye ars. These technologies are: 1) Cold Water Cleaning Systems; 2) the Resolve TM Dry Cleaning System; 3) the Impress TM 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 det ergents to clean garments. Garments are washed in chilled water which ranges i n temperature from 36 ° F to 39 ° F. The use of chilled water is expected to minimize sh rinking and may leave the use of tensioning equipment at the discretion of the dry c leaners. (ARB, 2004f)II-6

2. Resolve  Dry Cleaning System

Resolve  (Resolve) is a new dry cleaning technology that us es dipropylene glycol normal butyl ether (DPNB). DPNB is a solven t 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 literatur e, the Resolve system is able to take advantage of the low volatility of DPNB and uses li quid CO 2 in the same equipment to extract the DPNB from garments without the use of h eat. The garments can then dried by depressurizing the system to a gaseous state. R esolve 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. Thi s solvent is readily biodegradable and compatible with hydrocarbon machines. Accordin g 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 gly col ether, Impress is considered a VOC. According to Lyondell Chemical Company, Impre ss dry cleaning solvent is of low acute toxicity by oral and dermal (skin) exposu re. Further tests for toxicity assessments are underway. (ARB, 2005e; ARB, 2005f)

4. Hydroclene Fluids

Hydroclene is a mixture of normal-, iso-, and cycl o-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 a nd safety issues of all the technologies described above, especially for conver ted 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 choic e. The flammability details and the summary of flash points and classification for vari ous commonly used solvents are presented in Chapter VI, Table VI-1. Detailed info rmation on products, technical data, as well as material safety data sheet (MSDS) are av ailable by contacting the manufacturers. Appendix I lists the alternative so lvents 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, wit h 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 emissio ns can be controlled by using proper emission control and ventilation technologies to fu rther reduce or capture emissions.

A. Emission Control Technologies

Over the past several years, the use of Perc reco very devices has become common in the dry cleaning industry because of econ omic considerations, environmental concerns, worker exposure concerns, a nd regulatory actions. Emission reduction from the dry cleaning industry can be att ained through the use of proper operating practices and control equipment. These g reatly increase the amount of solvent being recycled while at the same time minim ize 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, refrigera ted 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 nei ther exhaust to the atmosphere or workroom nor generate additional solvent-contaminat ed waste water (where applicable). Today, the most commonly used primary control device is the refrigerated condenser. In the past, carbon adsorbers and polym eric 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 dry ing cycle, in which solvent-laden air is continually recirculated throu gh 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 solven t 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, a nd then flows through the condenser again where the solvent is recovered. (A RB, 1996)

In some hydrocarbon systems, the refrigeration uni t is divided into separate segments for simplified maintenance and reduced dow ntime. The compressor,III-2

refrigeration coil, and heat-exchange coil can be i ndividually serviced without removing the entire system. Sealed coils plus quick disconn ects prevent Freon  gas discharge. The refrigerated condenser keeps the temperature lo w during the drying cycle.

2. Secondary Controls

A significant source of solvent emissions from clos ed-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 - activ ated carbon bed contained in a housing), which operates in series with a refrigera ted condenser, can further reduce solvent vapor concentrations in the drum and, there fore, 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 v apor adsorber, which strips solvent vapors from the air. In order to keep operating ef ficiently, the carbon must be periodically regenerated. The regeneration process typically uses heat to strip and recover the adsorbed solvent. This desorption pro cess 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 th at 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 approv al of the secondary control systems, some systems can reduce the Perc concentra tion to below 100 ppmv. There are no similar statewide requirements for other sol vents.

3. Other Control Technologies

Inductive door fans may be installed to further red uce fugitive emissions. This device, which draws air through the loading door an d drum when the loading door is opened, is also beneficial in protecting the machin e 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 implement ed in several different ways. Ventilation is important as it affects the dispersi on of solvent vapors and other airborne compounds in the facility which in turns impacts th e 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 fa cility owner most likely had little or no input into the design and construction of the venti lation system. Newer facilities tend toIII-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 syst ems. This means that solvent vapors, such as Perc, are emitted from doors, windo ws, roof vents, and other openings throughout the facility. Natural ventilation depen ds upon wind and convective forces to move air and is typically considered the least effe ctive.

2. Window Fans

Window fans or wall fans are high flow rate prope ller type fans that are installed vertically in a wall (window-type-opening). The ai r is exhausted horizontally, typically near ground level. These also provide an improveme nt to a facility with only natural
ventilation.

3. General Ventilation

General ventilation systems typically have one or m ore large capacity fans on the roof of the facility. Capture efficiency depends o n 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 v entilation.

4. Local Ventilation

Local ventilation is a phrase used to describe a ve ntilation system with a high capacity fan, exhaust stack, and physical apparatus /structure (fume hoods, shrouds, flexible walls, vertical plastic strips) near the d ry 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 cros s-flow drafts and provide better capture of fugitive emissions.

5. Partial Vapor Rooms

A Partial Vapor Room (PVR) encloses the back of a d ry cleaning machine in a small room with the front panel and loading door ex posed for convenient loading and unloading. As a result, PVRs are able to more effe ctively 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 wi ndows 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 ro oms (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 mach ine 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 equ ipped with a self-closing device. Design features may vary, but normally include a “s winging” 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 c urrently required for co-residential dry cleaning facilities in the San Francisco Bay Ar ea 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 s everal surveys, site visits of dry cleaning facilities, and emission testing. Thi s 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, mach ine(s) type, solvent usage, waste produced, and maintenance information. Because of the large percentage of Korean dry cleaners, the Facility Survey and the cover let ter 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 compi led based on listings from Dun
and Bradstreet and the local air districts. The li sts were combined and duplicate addresses were deleted. With the help of Antelope Valley Air Pollution Control District (APCD), Mojave Desert Air Quality Management Distri ct (AQMD), and Ventura County APCD, over 6,300 Facility Surveys were sent in Sept ember 2003. The returned Facility Surveys were checked for address accuracy via yellow pages on the Internet. When needed, the facilities were called to verify a ddress 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 ad dress was deleted from our database.

In all, around 5,800 Facility Surveys were delivere d 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 facilit ies with dry cleaning machine(s) on-site was 1,634. Assuming the 14 percent proport ion 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 sh ops in the State.

During early 2004, the completed Facility Surveys w ere reviewed to see if they were from drop off shops or if they were from dry c leaners that operate machine(s) on-site (dry cleaning plants). The drop off shop r eturns were compiled and accounted for while the Facility Surveys from dry cleaning pl ants 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 en try was compared with the original Facility Surveys for accuracy. During survey analy sis, the Facility Survey results were compared with site visit results. In most cases, t he site visit results were reasonably similar to the Survey results.IV-2

2. Business Information

Dry cleaners in California are mostly small busines ses employing less than five employees. After equating 40 part-time hours worke d 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 cl eaners are usually independently owned and often are operated by the owner and/or th e 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 altera tion. The industry is highly competitive; even though almost half of the facilit ies 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 bo th newly opened facilities and new owners of existing facilities. A summary of the di scussed business information is shown
in Table IV-1.

Table IV-1. Business Information

Years Owned Facility Percent 1

< 1 7
≥ 1 and < 5 25
≥ 5 and <10 19

≥ 10 and < 20 37
≥ 20 12

Business Status Percent 1
Independently Owned 98 Chain Operation 1

Franchise 2

Annual Receipts From Total Operation Percent 1

Less than $100,000 40 $100,000-$500,000 55 $500,000 – above 5

Percent Annual Receipts From Dry Cleaning Only Percent 1

Less than 25% 7

25-50% 18

50-75% 48
More than 75% 27

Number of Equivalent Employees 2 Percent 1

≤ 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 a nd 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 n oted that practically all dry cleaning facilities are open from Monday through Fr iday (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 an d 7:00 PM in the evening from Monday through Friday. Our Facility Survey also sh owed 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 Bus iness Hours

Business Hours Percent 1
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 m aterial that is dry cleaned include clothing, curtains, sleeping bags, blankets , comforters, and leather goods (ARB, 1993a). Other business types make up less th an five percent of the total and include: industrial dry cleaners, nonprofit organi zations, and hotels/motels. This is similar to the findings of the survey the Californi a Air Resources Board (ARB) conducted in 1991 (1991 Survey). A comparison of the busines s 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 u nless they are less than 1 and may not add up to 10 0.

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 us e Perchloroethylene (Perc) as the
solvent.IV-4

Besides Perc, the second solvent of choice is DF-20 00 TM Fluid (DF-2000), a high flashpoint, synthetic hydrocarbon solvent manufactu red by ExxonMobil. Other alternative solvent/processes include: PureDry  (PureDry), GreenEarth  (GreenEarth), Rynex TM (Rynex 3), carbon dioxide (CO 2 ) cleaning, water-based cleaning systems, such as Professional Wet Cleaning (wet cleaning) and Gre en 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 CO 2 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 s ummary of the operating information
is listed in Table IV-4.

Table IV-4. Summary of Operating Information

Number of Dry Cleaning Machines Percent of Facilities 1

1 92

2 8

More than 2 < 1

Solvent Type Percent of Machines 1,2

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 Entry 1

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 1 00. 2. Values added to over 100 because of multiple e ntries 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 o n 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 mean t laundry and the Facility Survey result was adjusted accordingly. Currently, there are 37 dedicated wet cleaningIV-5

facilities and 43 facilities that use wet cleaning together with another type of dry cleaning process (mixed shops) in the South Coast A QMD (ARB 2005c). Facilities that use wet cleaning outside of the South Coast AQMD ar e mostly mixed shops.

In addition, as shown on Table IV-4, the Facility S urvey 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, t he 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 F acility Survey. None of the facilities that responded to the Facility Survey use the solve nts Rynex 3 and EcoSolv. Currently, we know that Rynex 3 is being used by two facilitie s 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 sy stems and CO 2 cleaning, dry cleaning machines usually operate with a water separator, wh ich generates wastewater. Because separator water from a Perc dry cleaning ma chine 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 trea tment units: evaporator, atomizer, and liquid discharge. The categories spe cify the method of waste effluent elimination, i.e. evaporators would eliminate the w aste 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 ha ve their wastewater collected by a waste hauler. There is also a small percentage of dry cl eaners (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, the y are either new facility operators or operate one of the alternative dry cleaning process es.

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 secondar y controls (secondary). Transfer machines in use today are for wet cleaning or for c leaning 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 mac hines in operation are primary machines and about a third of the machines are secondary machines. TheIV-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 n ew.

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 Percent 1

Transfer 1 Primary Control 62 Secondary Control 28 Converted (vent to no-vent) 2 Wet Cleaning 2

1. Values are rounded off to the neares t integer unless they are less than 1 and may not a dd up to 100.

The machine age and capacity were grouped and compa red 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 ave rage age of Perc converted machines is 16 years, and it is six years older tha n that of Perc primary machines. The average age of Perc primary machines is 10 years an d it is 6 years older than that of Perc secondary machines. In general, the machine a ge of the alternatives is lower than that of the Perc machines. The machine age compari son is shown in Figure IV-1 below. As shown in Figure IV-1, the age of DF-2000 machine s, with an average of 2 years is 2 years newer than that of the Perc secondary machi nes.

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-2000IV-7

The machine capacity is shown in Figure IV-2. The median machine capacity for each of the machine type plotted can be obtained fr om Figure IV-2 by looking at the capacity of that machine type that corresponds to 5 0 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 th e Perc secondary machines up to about 85 percent. There is a slight increase in ca pacity when comparing Perc secondary machines to Perc primary machines; the me dian capacity for Perc secondary machines is 45 pounds while that for the Perc prima ry machines is 40 pounds. When comparing DF-2000 machines, they are generally slig htly larger than the Perc secondary machines. The DF-2000 machines have a me dian capacity of 50 pounds.

Figure IV-2. Machine Capacity

Based on time of machine operation, the operation d uration is about six hours each day for five or six days of the week. Th e machine operation start and end times are shown on Figure IV-3. As shown on Fi gure IV-3, although machine start time varies, around 80 percent of the facilities start machine operation by 8:00 AM; therefore, about 20 percent o f the facilities start machine operation after 8:00 AM. Correspondingly, around 8 0 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 garm ents immediately follows machine operation during the early part of the day because it involves steam presses which generate heat. One noted exception i s wet cleaning. Because clothing from the wet cleaning process may not be p rocessed 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-2000IV-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 Machin e Operation

The number of days of machine operation in a week i s 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 perce nt of the facilities that operate their machines for six days. The remaining facilities, a bout six percent, operate either seven days or less than five days.

Table IV-6. Days of Machine Operation

Number of days per week Percent 1

5 days 55 6 days 39
Others 6

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

5. Facility Size

One of the tools that are used to estimate potentia l 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 facili ty 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

10 20 30 40 50 60 70 80 90 100

0

Percent of Facilities (%)Time

Start Time

End TimeIV-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 fac ility 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 un der 1,100 sq. ft; therefore, about 90 percent of the dry cleaning facilities have facilit y areas that are over 1,100 sq. ft. Also, as shown on Figure IV-5, about 50 percent of the dr y cleaning facilities have heights that are lower than 12 ft; therefore, about 50 perc ent 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 abov e or next to a dry cleaning facility (co-location information) and receptor dis tances to facilities were obtained from the Facility Survey. The type of receptors include d businesses, residences, schools, day care facilities, hospitals, and senior communit ies. This information helps to
characterize the location of the facilities and wil l be considered during risk assessment. A summary of receptor distances is shown on Table I V-7.

As shown on Table IV-7, about two percent of the f acilities 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 ar e 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 75IV-10 Table IV-7. Summary of Receptor Distances 1

Information on Co-location Percent of All Facilitie s 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 Per cent
≤ 100 feet <1
≤ 500 feet 3

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

7. Ventilation Type

Ventilation type is used to identify emission relea se parameters that are needed for air dispersion modeling. On the Facility Surve y, 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 ven tilation 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 inform ation gained through site visits, we categorized the ventilation information obtained in to all six ventilation types. These six ventilation types are: natural ventilation, wall f an, 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-po wered ceiling fans, and/or passive roof vents. Wall fan (or window fan) is the catego ry for facilities that have, in addition toIV-11

natural ventilation, a high capacity wall fan. Gen eral 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 th e 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 f ugitive 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 Facili ty Survey is listed on Table IV-8.

Table IV-8. Ventilation Information

Type of Ventilation Percent 1

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 ad d up to 100.

As shown on Table IV-8, about half of the facilitie s 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 ven tilation in the Facility Survey. The
ventilation information was modified based on the v erification and is detailed discussion in Section B.

8. Maintenance Information

Maintenance practices were obtained from the Facili ty Survey. Facility operators were asked how often they inspect the machine(s), w hat type of leak detector is used during inspection, how many certified operator(s) a re on-site, and how often they regenerate the carbon in the secondary control mach ines. 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 resul ts 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 fi ve 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 F acility Survey, leak checks are performed using a halogen leak detector (TIF detect or) by a majority of the facilities. The TIF detectors that are used in the industry can start detecting Perc at aroundIV-12

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

About 16 percent of the facilities have more than o ne certified operator with about 84 percent having only one certified operator . Although the alternative dry cleaning facilities are not required by the Dry Cle aning ATCM to have a certified operator on site, all responded that they have at l east 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 perce nt of the facilities that have a secondary control machine would regenerate carbon a ccording to machine manufacturer’s specification, while about 30 percen t responded that the carbon is regenerated automatically. There is about three pe rcent 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 wou ld not be efficient in adsorbing Perc. The summary of the maintenance information i s tabulated on Table IV-9 below.

Table IV-9. Summary of Maintenance Information

All Users Perc Users Only Frequency of inspecting machine Percent 1 Percent 1
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 0 2

Number of certified operators on-site Percent 1 Percent 1

One 84 84

Two 14 14

More than 2 2 2

Frequency of regenerating carbon Percent 1 Percent 1

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 u nless they are less than 1 and may not add up to 10 0. 2. None reported.

9. Future Machine Purchase

The facility operators were asked whether they woul d buy a new or used machine if they had to replace their current machin e or purchase a new machine. They were further asked what type of solvent that machin e would use. As shown inIV-13

Table IV-10, most facility owners would opt to purc hase a new machine instead of a used one. Staff also observed this trend during si te visits, where only a few mentioned that they might purchase a used machine due to pric e 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 th eir 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 Percent 1

New 96
Used 4

Type of Solvent Percent 1,2

Perc 44
DF-2000 24 Rynex 3 2
Stoddard 3
GreenEarth 15 Liquid CO 2 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 en tries per facility.

Other information obtained from the Facility Survey is discussed in Section H. This information includes the amount of Perc purcha sed, 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 fa cilities around the State to get more
detailed data. The facilities were located in 66 c ities 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 Val ley Unified APCD, Shasta County AQMD, South Coast AQMD, Ventura County APCD, and Yolo/Solano AQMD. In addition, staff requested facility data from Mon terey Bay Unified APCD and Santa Barbara County APCD. In all, 11 local air district s, encompassing about 97 percent of the facilities statewide, are represented in the si te visit analysis.

Most of the facilities were selected randomly. Som e 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, a nd gathered general information fromIV-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 sho wn in Figure IV-6 on page IV-15.

The site visit facility information was compared wi th the Facility Survey results. The comparison of the amount of co-located faciliti es and the facility area and height is
shown in Table IV-11.

Table IV-11. Comparison of Amount of Co-location an d 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 resul ts 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 Receptors 1

Facility Survey
Results Site Visit Info

Distance to Nearest business Cumulative Percent Cum ulative 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 Cu mulative 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 Receptors 2 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 nea rest 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 San Bernardino Montclair La Crescenta Granada Hills

Pico Rivera Los Angeles, City of

Manhattan Beach
Hermosa Beach 

## Los Angeles Basin SitesIV-16

As shown on Table IV-12, there is reasonably good a greement between the Facility Survey and the site visit results on recep tor distances. Table IV-13 shows a comparison of Facility Survey and site visit result s on facility ventilation type.

Table IV-13. Comparison of Facility Ventilation 1

Facility Survey
Results Site Visit Info Bay Area AQMD Type of Facility Ventilation Percent Percent Percen t

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 1 00.

As shown on Table IV-13, there are significant diff erences between the Facility Survey and site visit results on some of t he facility ventilation data, with the LOC values having the greatest contrast. Because of th e 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 r equires enhanced ventilation when the potential cancer risk exceeds a certain level, hist orically 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, an d 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 a gree better with the site
visit results. To better understand this differenc e, staff conducted site visits to four Sacramento facilities that reported having LOC on t he Facility Survey. During the site visits, all four owner/operators explained that the y 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 p ercentages 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 ass ess list price of the dry cleaning machines. Other information requested inc luded: recommended maintenance schedule, maintenance cost, and machine brochures. The Machine Manufacturers Survey (shown in Appendix C) provided staff with cu rrent information on machine andIV-17

maintenance costs, recommended maintenance schedule /practices, and latest technologies available on the machines.

When compared to the cost of a secondary Perc machi ne, the cost of the commercially available water-based cleaning system is either similar or less. In contrast, all other closed-loop machines used for t he alternative solvents are generally higher in cost. The most costly machine type is th e one used for liquid CO 2 . Detailed cost information/discussion is presented in Chapter VII.

General maintenance practices for the closed-loop m achines 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 m ay include proper lubrication of machine parts, checking the pressure level, and cha nging the carbon for certain carbon filters and for secondary control machines. Theref ore, the time and effort spent on maintenance procedures are similar. For special ca ses where a still is not needed for some alternative solvents, there might be some decr ease 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 fi lters, 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 c artridge 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 mill ion (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 Man ufacturers Survey was sent to some of the alternative dry cleaning solvent manufa cturers. This survey was primarily a request for solvent formulation and therefore we di d not send out surveys to those solvent manufacturers where we already had informat ion on solvent formulation. After the survey, staff obtained adequate formulation inf ormation associated with petroleum solvent cleaning (DF-2000 TM Fluid, PureDry  , EcoSolv  , Shell Sol 140 HT, Stoddard), volatile methyl siloxane cleaning (GreenEarth  ), glycol ether cleaning (Rynex TM ), CO 2 cleaning, and water-based cleaning systems. Severa l 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 Su rvey) was developed to
assess the amount of Perc that is sold to the Calif ornia dry cleaning industry. Information for years 2001, 2002, and 2003 were gat hered from the distributors. A summary of the total amount of Perc bought and so ld by the distributors for those three years are shown in Table IV-14. Based on Tab le IV-14, the majority of the Perc that was purchased was sold to the dry cleaning ind ustry. 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 purchas ed by the dry cleaning industry was calculated based on the Facility Surve y. 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 mac hines about 85, the usage can be estimated from facility survey. The result is comp ared with the Distributors Survey in Table IV-14. As shown on Table IV-14, the Distribu tors Survey results compare well with the facility survey results and there is a gra dual decrease in the amount of Perc sold to the dry cleaning industry.

Table IV-14. Summary of Perc Usage 1

Sold to Dry Cleaning Industry In 2000 (Gallons) Sold to Dry

Cleaning Industry In 2001 (Gallons) Sold to Dry

Cleaning
Indus try In 2002 (Gallons) Sold to Dry

Cleaning Industry In
2003 (Gallons) Distributors Survey N/A 2 378,000 346,000 320,000

Facility Survey 393,000 381,000 365,000 N/A 3

1. Values are rounded off to the nearest thousand. 2. Value was not obtained from the Distributor Sur vey. 3. Value was not obtained from the Facility Survey

.

The values obtained from the Distributors Survey ar e low when compared to an estimate by the Halogenated Solvents Industry Allia nce, Inc. (HSIA). They estimated, based on population, that the volume sold to Califo rnia 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 s uggests that the California dry cleaning industry uses less Perc than the national average. In addition, current information from the Perc producers of 323,000 gall ons 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 2 003. (ARB, 2005e).

F. Perc and DF-2000 Sludge Test Results

To support emission analysis of the dry cleaning pr ocesses, liquid sludge from
Perc machines and DF-2000 machines was tested for s olvent content. The standardIV-19

operating procedures for determining Perc and DF-20 00 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 wi th South Coast AQMD data is
shown in Table IV-15.

Table IV-15. Summary of Perc and DF-2000 Sludge Tes ts

Machine Type Number of

tests Wt%

Solvent
in Sludge 1 Weighted

Average
Wt% Solvent
in Sludge 1 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 d ensity. These weighted average values are used in emission calculations shown in S ection H. Comparing the ARB and South Coast AQMD values for the weight percent of s olvent in sludge shows the values obtained for the Perc secondary test series to diff er by only two percent; however, for the Perc primary and the DF-2000 test series, the d ifference 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, t he 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 an d South Coast AQMD test series combines the two sets of data to provide more repre sentative data.

G. Leak Detector Evaluation

Based on observations during site visits and conver sations with ARB training staff and local air districts, Some Perc facility o perators do not use their halogenated hydrocarbon detector (HHD) as often as they are req uired. The reason is that most of the HHDs do not give quantitative results. A major ity of the Perc facilities use HHDs made by TIF TM Instruments, Inc. (TIF detectors) that would beep when Perc or other volatile organic compounds (VOCs) were detected. T he threshold level for beeping to begin is around eight ppm (ARB, 2004c). The TIF de tectors can not be easily used toIV-20

accurately determine whether a facility is in viola tion 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 f or Perc detection and conducted a limited evaluation. Ten portable detectors, in a ddition to a TIF detector and a photoionization detector (PID) that was available a nd served as reference, were evaluated. The range of technologies tested includ ed: PID, gas sensitive semiconductor, colorimetric tube, infrared, and hea ted diode sensor technology. Cost information for the detectors is shown in Chapter V II. The evaluation included two phases. During the first phase, the detectors were evaluated under laboratory conditions to determine detection accuracy and resp onse time to Perc standards. During the second phase, a TIF detector, the refere nce 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 com pare detector response time to Perc levels around the machines, to actual leaks, and we re used to measure background
Perc concentrations within the facilities.

A memorandum (memo) from ARB’s Monitoring and Labor atory 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 ev aluation results, staff tested nine detectors in dry cleaning facilities. Two of the n ine detectors were modified Aeroqual
detectors that included a built-in fan in the senso r head. In addition to the nine detectors, staff also tested the TIF detector and c ompared readings with a PID (manufactured by PE Photovac International Inc.) us ed 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 w ell and provided quantitative results. The Aeroqual 200 Leak Detector (different from the Aeroqual 200 used for monitoring purposes) was also deemed suitable for l eak 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 diff usion for sample delivery had response times of 5 seconds or more in the field an d were deemed not suitable for leak
detection. The Tek-Mate and the TIF-5100 were sens itive to Perc and will indicate leaks at levels below 50 ppm. The facility backgro und concentrations were mostly
non-detectable with the limit of detection of the P ID detectors at around 1 or 2 ppm; the largest background concentration reading was betwee n 5 to 10 ppm.IV-21 Table IV-16. Summary of Leak Detector Evaluation

Model and (Manufacturer) Detection Principle Sample

Delivery Display Response Time 1 (sec) Leak Check

Suitability 2

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 fan 3 (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 Response 4 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 fo r the detector to display a stable concentration. 2. Leak check suitability based on response time o f 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 requir e humidified gas sample.

H. Emissions from Dry Cleaning Operations

Emissions from dry cleaning operations are calculat ed based on a material balance approach. The amount of solvent that is co nsumed by a dry cleaning operation
is either emitted into the air or is embedded in th e waste or in clothes that are removed from the facility. Equation 1 shows the material b alance relationship.

(1) Solv e = Solv c - Solv w - Solv clothes

where: Solv e = volume in gallons of solvent emitted to th e atmosphere from

a dry cleaning facility, Solv c = volume in gallons of solvent consumed in a dry cleaning facility,IV-22

Solv w = volume in gallons of solvent that exit a dr y cleaning facility in

the waste products, such as still bottom, separator water, and used cartridge filters, and Solv clothes = volume in gallons of solvent that exit a dry cle aning facility in

clothes.

Information from our workgroup and from our site vi sits showed that a three-year average of solvent purchased is a good indication o f the amount of solvent used by a machine each year. The exception will be newly pur chased 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 sol vent used by a dry cleaning machine in California can be estimated from purchas e amounts after excluding the newly purchased machines. For example, the three y ear 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 calcul ating 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 approxima tely 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 w ould be left with a small subset of data. Since the difference in solvent usage from n ewly purchased machines occur during the first year of machine operation, it is a ssumed that excluding machines that were purchased in 2002 and using average 2002 solve nt purchases would be a good approximation of average solvent consumption for DF -2000 machines. The average DF-2000 consumption calculated is 89 gallons per ye ar. This assumption was compared with Perc secondary machine data and the c alculated 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 solve nt consumed, three-year average of clothes dry cleaned, solvent consumed, s till bottoms generated, and the
number of filters used for facilities that used Per c primary machines, Perc secondary
machines and DF-2000 machines. As shown on Table I V-17, there are three types of cartridge filters that are used in the machines. T hese 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 combinatio n of the three types of cartridge filters and they are designated as such on the tabl e. In addition to cartridge filters, a portion of the machines have spin-disk filters. Th ere 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-po wered 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 u sed 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 Sur vey data) and the weight percent ofIV-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 calculati on. 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 pri mary machines of 45 percent and an average density of 10.12 pounds (lbs) per gallon, t he 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 calcul ated 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 prod uced by a primary machine is about 141 gallons (from Facility Survey, Table VI-1 7). The Perc content in separator water was measured during an ARB test program in 19 97 and by an affiliate of ATC Associates Inc. (AVES). The average Perc content i n 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 A nalysis

Emission Analysis Information Perc Facilities

Primary Machines Secondary Machines DF-2000
Facilities

Amount of clothes cleaned Pounds 1 Pounds 1 Pounds 1
Average 44,000 52,000 53,000

Yearly solvent usage and waste produced Gallons 2,3 Gallons 2,3 Gallons 2,4

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 Count 2,3 Count 2,3 Count 2,4
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 Percent 3,5 Percent 3,5 Percent 4,5
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, u nless it is less than one. 3. Values are averaged from three years of data, ex cluding 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 un less they are less than one and may not add up to 1 00 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, 2 000). 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 emi tted 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 e stimated to be one gallon (ARB, 2004a). For example, for a facility that use s 13 standard filters a year, the amount of Perc that is disposed of in the filters i s about seven gallons.

A detailed look into machine types and amount of em issions shows that secondary machines are more efficient in Perc use c ompared to primary machines and
converted machines. Because the number of converte d machines is low (two percent of the total), it was not further divided into cate gories based on filter types. Within the categories of primary machines and secondary machin es, the type(s) of filters used were identified and checked for difference in perfo rmance. There are three categories based on filter types: spin disk only, cartridge o nly, 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 dis k filters. The combo category represents machines that have a combination of spin disk and cartridge filters. The percentage of each category is obtained from Facili ty Survey data and is shown on
Table IV-18.

The amount of sludge, separator water, and number o f filters used for converted machines and for each of the categories of primary and secondary machines was obtained from the Facility Survey. The emissions a re then calculated based on Equation 1 and are then normalized to the same amou nt of material dry-cleaned (46,600 pounds per year). A comparison of the norm alized 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 ma chines having lower emissions, and the secondary machines emitting the least amoun t 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 filte rs and a combination of spin disk and cartridge filters versus those that use cartrid ge filters only. Primary machines that operate with only cartridge filters emit about 41 p ercent 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 w hen 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 Comparison 1

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 mate rial cleaned per year and rounded off to the neares t 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 Per c may result in both cancer and non-cancer effects. There are many human and a nimal 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 Assessmen t (OEHHA) staff has performed an extensive assessment of the adverse he alth effects of Perc, including available carcinogenicity data. Summary information on human and animal studies can be found in OEHHA’s Air Toxics H ot Spots Program Risk Assessment Guidelines, Part II, Technical Support D ocument for Describing Available Cancer Potency Factors, April 1999

.

The Air Resources Board (ARB) formally identified P erc as a toxic air contaminant in 1991. OEHHA concluded that Perc is a possible human carcinogen with no identifiable threshold below whi ch no carcinogenic effects are likely to occur. Under Proposition 65, the Safe Dr inking Water and Toxic Enforcement Act of 1986, the State of California li sted Perc as a carcinogen in April 1988. In 1990, the United States Congress li sted Perc as a hazardous air pollutant in subsection (b) of Section 112 of the f ederal Clean Air Act (42 U.S.C. 7412). The International Agency for Res earch on Cancer (IARC) has classified Perc in Group 2A, as a probable human ca rcinogen. The United States Environmental Protection Agency (U.S. EPA) i s 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 irritati on or burns on the skin, eyes, or respiratory tract. Chronic exposure to lower Pe rc concentration levels may result in dizziness, diminished cognitive ability, and damage to the liver and kidney (ARB, 1993). Workers have shown signs of li ver toxicity following chronic exposure to Perc, as well as kidney dysfunction and neurological effects. Effects on the liver, kidney, and central nervous systems f rom chronic inhalation exposure to Perc have been reported in animal studi es (ARB, 1997).

1. Pollutant-specific Health Values

Dose-response or pollutant-specific health values are developed to characterize the relationship between a person’s ex posure to a pollutant and the
incidence or occurrence of an adverse health effect . A cancer potencyV -2

factor (CPF) is used when estimating potential canc er risks and reference exposure levels (RELs) are used to assess potential non-cancer health impacts. Dose-response or pollutant-specific health values a re developed to characterize the relationship between a person's exposure to a p ollutant and the incidence or
occurrence of an adverse health effect.

The CPF, which is currently used for health risk as sessment, describes the excess cancer risk associated with exposure to one milligram of a given chemical per kilogram of body weight. The inhalati on unit risk factor (URF), which was used in the past for health risk assessme nt, is defined as the estimated upper-confidence limit (usually 95 th percentile) probability of a person contracting cancer as a result of constant exposure to a concentration of 1.0 microgram per cubic meter (μg/m 3 ) over a 70-year lifetime. The URF of
5.9x10 -6 (μg/m 3 ) -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 tw o significant figures. The factor of 3,500 is derive d from a 70 kilogram (kg) human body weight, 20 m 3 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 popu lation. RELs are designed to protect the most sensitive individuals in the popul ation by including uncertainty factors in their development and are created for bo th 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 exposu re is defined as long-term exposure usually lasting from one year to a lifetim e.

As mentioned previously, exposure to Perc may resul t in both cancer and
non-cancer effects. Table V-1 shows the health val ues 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 solven t for which there are adopted health values available for use in California. OEH HA 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 2.0x10 4 μg/m 3
Chronic inhalation REL 35 μg/m 3

Inhalation unit risk factor 5.9x10 -6 (μg/m 3 ) -1
Inhalation cancer potency factor 2.1x10 -2 (mg/kg-d) -1V -3

B. Perc Alternatives

There is relatively little health data available on the alternatives and no California health values have been adopted. As a r esult, ARB staff requested OEHHA to review the health effects of alternative d ry 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 m any of these compounds. Based on their literature review, OEHHA has estimat ed several interim RELs and is continuing to follow the peer-reviewed literatur e on toxicity studies for the
alternative solvents.

1. Hydrocarbon Solvent Cleaning (DF-2000, PureDry, EcoSolv, Shell 140, Stoddard)

Hydrocarbon solvents, sometimes referred to as mine ral spirits and petroleum solvents, are mixtures of hydrocarbons wi th or without other materials. Hydrocarbons have been used in the dry cleaning ind ustry for many years and
are some of the more common alternatives to Perc dr y cleaning. The hydrocarbon solvents are a unique mixture of carbon and hydrogen molecules that co-exist as linear and branched chains, as wel l as in cyclic forms (U.S. EPA,1998).

For Stoddard solvent, the American Conference of Go vernmental Hygienists set a Threshold Limit Value (TLV) of 525 mg/m 3 . The National Institute for Occupational Safety and Health (NIOSH ) REL is 350 mg/m 3 time-weighted average (TWA). Stoddard solvent can be irritating to the eyes, nose, throat, and can also have effects on the nerv ous system. (U.S. EPA, 1998)

A recent two-year inhalation study of Stoddard solv ent conducted by the National Toxicology Program (NTP) concluded that th ere 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 identif ied the kidney and liver as the major target organs (NTP, 2004).

There is also very limited health information on ot her hydrocarbon
mixtures. DF-2000  Fluid (DF-2000) contains C 11 to C 13 synthetic isoparaffin aliphatic hydrocarbons. PureDry  (PureDry) contains 95 percent mineral spirits, which can cause neurotoxicity, and eye and respirat ory irritation at high concentrations (OEHHA, 2003). EcoSolv  (EcoSolv) and Shell Sol 140 HT have similar hydrocarbon properties.

Most information is lacking on the environmental pe rsistence of these and other hydrocarbon mixtures, however the manufacture r of DF-2000 indicated thatV -4

their solvent can exhibit moderate rates of biodegr adation (ExxonMobil, 2003).
The manufacturer of EcoSolv indicated their solvent can exhibit moderate to rapid rates of biodegradation (Chevron Phillips, 20 05).

For hydrocarbon mixtures, OEHHA has developed an in terim chronic REL of 1,200 μg/m 3 . 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 st udy can be found in Appendix G. The scarcity of health information for hydrocarbon solvents is a concern. Although the limited data available indic ates relatively low toxicity, there are no comprehensive studies which indicate t hat toxicity and carcinogenicity should not be a concern. More rese arch in this area is needed before a better assessment of the health impacts fr om hydrocarbon emissions
can be made.

An occupational exposure limit (OEL) can be calcul ated for various hydrocarbon solvents. Guidance values for individu al hydrocarbon constituents or groups of constituents were recently published i n an article A Proposed Methodology for Setting Occupational Exposure Limit s for Hydrocarbon Solvents in the Journal of Occupational and Environmental Hy giene, 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 D 5 , 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 produ cts. D 5 is present in
GreenEarth  (GreenEarth) solvent. Dow-Corning, who manufactur ers the solvent, conducted a two-year study with rats in wh ich preliminary data showed
an increase in tumors of the uterine endometrium. Preliminary findings may indicate that there is a potential carcinogenic haz ard associated with D 5 (U.S. EPA, 2003). The observance of adverse effect s on the uterus by D 5 is of concern (OEHHA, 2003). Because D 5 is lipophilic there is also concern that D 5 may bioaccumulate in the food chain.

A study by Burns-Naas et al . (1998) evaluated the subchronic toxicity of
D 5 . This study showed there were several minor chang es observed in clinical biochemistry parameters; the most notable was an in crease in gamma glutamyl transferase (a liver enzyme) in both sexes at the h igh dose. This study also showed that there was an increase in liver weight i n rats. McKim et al. (1999) investigated the effects of D 5 on the expression and activity of selected rat hepatic phase I and phase II enzymes. Additional i nformation on the Burns-Naas
et al . and McKim et al

. studies can be found in Appendix G.V -5 In June 2005, D 5 manufacturers submitted final toxicity testing dat a to ARB, OEHHA, Department of Health Services (DHS), an d U.S. EPA. According
to D 5 manufacturers, this data supports their conclusion that D 5 is safe when used as intended. After ARB, OEHHA, DHS and U.S. E PA review the data, a better assessment of the public health impacts from GreenEarth emissions can
be made.

3. Rynex TM (Propylene Glycol Ether)

Rynex TM (Rynex 3) is a form of propylene glycol ether and water. This solvent had some changes in formulation since its i nception. Rynex 3 represents the current formulation for Rynex 3. Currently, th ere is limited toxicity data on Rynex 3.

Based on a recent study by NTP on a previous formul ation for Rynex 3, propylene glycol t-butyl ether, OEHHA expressed con cerns over its toxicity and carcinogenic potential. Of particular concern was the presence of tumors in mice. OEHHA has developed an interim chronic REL f or propylene glycol t-butyl ether of 200 μg/m 3 to prevent adverse effects in the respiratory syste m. In addition, an interim inhalation unit risk factor fo r cancer was estimated to be
5.2x10 -7 (μg/m 3 ) -1 , about one-tenth that of Perc. There are no devel opmental or reproductive studies on the chemical. Appendix G h as more detailed information on the toxicological studies for the previous formu lation of Rynex 3, propylene glycol t-butyl ether.

The manufacturer of Rynex 3 has indicated that Ryn ex 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 expo sure to ethylene glycol ethers (Rynex, 2005a). However, neither ARB nor OEHHA sta ff has verified this or has received these toxicological studies.

4. Carbon Dioxide Cleaning

As discussed in Chapter II, carbon dioxide (CO 2 ) cleaning uses liquid CO 2

. The CO 2 used in this process is an industrial by-product. There is no net increase in the amount of CO 2 emitted; therefore, this process does not contribute to global warming. CO 2 is naturally occurring and is routinely ingested in food products such as soft drinks. CO 2 is also used in packaging for many foods such as salads, potato chips, and cookies.

Design for the Environment (DfE), a cooperative pro ject between the U.S. EPA and the garment and textile care industry, recognizes the CO 2 cleaning process as one example of environmentally preferabl e technology that can effectively clean garments. The DfE conducted a ca se study on a Micell Technologies, Inc., CO 2 system that uses CO 2 in conjunction with a cleaningV -6

agent that enhances the cleaning ability of the liq uid CO 2 . In the case study, Micell Technologies asserts that their cleaning sys tem offers excellent cleaning performance across most garment components and a wi de range of stains and soils. This system uses the same beverage-grade bulk CO 2 that is distributed to more than 50,000 restaurants and other fountain bev erage 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 formu lations, there is difficulty with determining toxicity of these substances. Chemical s used in wet cleaning process commonly include spotting agents, detergent s, fabric conditioners and sizing products. Other products may be used for cl eaning leather and suede including water repellants.

In general, detergents are approved for disposal in to the sewer system by the sanitation districts. U.S. EPA examined the hu man health and environmental hazards of surfactants because they are the primary components of detergents. In general, they found that there was no expected h ealth 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 (IRT A, 2005).

In U.S. EPA’s Cleaner Technologies Substitute Assessment: Profes sional
Fabricare Processes

(CTSA), U.S. EPA provided health hazard summaries on surfactants and surfactant aids for some example de tergents. The following surfactants were included in their example detergen ts: 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 curren tly being used. Below is
some health information on some of the surfactant a nd 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 ethe rs exhibit very low oral toxicity, and no neurologic, reproductive, or mutagenic effec ts. (U.S. EPA, 1998)

CAPB is reported as a potentially irritating substa nce. CAPB does not appear to have undergone any studies of reproductiv e or developmental toxicity or neurotoxicity or chronic studies of systemic eff ects. 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 ingesti on and to exhibit little or no potential for skin irritation and sensitization. ( U.S. EPA, 1998)

No human studies were located regarding the potenti al 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 “mod erately to slightly toxic” in acutely exposed animals and virtually non -toxic in chronically exposed animals. SDS does not appear to exhibit any reprod uctive, developmental, or carcinogenic effects in animals. (U.S. EPA, 1998)

Limited information on SLI suggests that this chemi cal 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 s evere irritation in both humans and animals. Based on short-term mutagenici ty tests, acetic acid does not interact with genetic material. Although no di rect information on the carcinogenicity of acetic acid was located, one chr onic 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 huma ns following inhalation or dermal exposure. No information has been located d iscussing neurotoxic, mutagenic, or carcinogenic effects associated with citric acid exposures in animals or humans. Sodium citrate is expected to b ehave chemically like citric acid systemically, but may not have the irritant pr operties. (U.S. EPA, 1998)

Sodium carbonate is a skin and eye irritant. Sodiu m carbonate is not developmentally toxic to mice, rats, or rabbits. N o 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) stat es that the product is 100 percent biodegradable. It also states that it cont ains no petroleum solvents,V -8

volatile organic compounds, or products from the fe deral 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-prop yl bromide, also known as 1-bromopropane, is a solvent that is currently b eing considered as an alternative to dry cleaning. This compound is a ne urotoxicant and reproductive toxicant (OEHHA, 2003) and was listed under Proposi tion 65 as a reproductive toxicant in December 2004. It causes sterility in both male and female test animals, and harms developing fetuses when tested i n pregnant animals. It can damage nerves, causing weakness, pain, numbness, an d paralysis (CDHS, 2003). Because this is a relatively new che mical, 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 tox icity 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 dev eloped interim values for some of the dry cleaning alternatives. Interim RELs are estimates based on approved OEHHA procedures; however, interi m values have not gone through public comment and scientific peer review. OEHHA is continuing to follow the peer-reviewed literature on toxicity stu dies for the alternative solvents. Table V-2 summarizes these values. Refer to Append ix 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 REL 1 Chronic REL Cancer potency factor 1
D5 (GreenEarth) N/A 700 μg/m 3 N/A 1-Propyl bromide N/A 1,100 μg/m 3 N/A Hydrocarbon mixtures N/A 1,200 μg/m 3 N/A Hydrofluoroether (HFE 7200) (a compound in PureDry) N/A 19,000 μg/m 3 N/A

Perc 2 2.0x10 4 μg/m 3 35 μg/m 3 2.1x10 -2 (mg/kg-d) -1

1. N/A means not available - not enough health dat a is available to determine a health value for this compound. 2. The values for Perc are approved by OEHHA and a re included for comparison.VI -1



### VI. ENVIRONMENTAL IMPACTS

Several potential environmental impacts have been i dentified that are associated with the use of dry cleaning alternatives and perch loroethylene (Perc). This chapter discusses the impacts on wastewater, groundwater co ntamination, 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 sewer s. 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 indust ry appears to be low due to the changes in dry cleaning operations and the implemen tation of environmental regulations (NC, 2001). Based on information gathered from the Dry Cleaning Facility Survey (Facility Survey), dry cleaning facilities using Pe rc either use a wastewater treatment unit to recycle their Perc or they have their waste water picked up by a registered hazardous waste transporter (in California, all haz ardous waste must be managed offsite by a transporter that is registered with th e California Department of Toxic Substances Control). It should be noted that spott ing chemicals can also be a source of
Perc.

In general, it is prudent to check with the local p ublicly owned treatment works in the State before discharging any wastewater into th e sewer. However, potential wastewater impacts of the alternative solvents were assessed based on available information. The carbon dioxide (CO 2 ) cleaning process does not generate wastewater and would not have an impact. Dry cleaners that us e other alternative solvents, including GreenEarth  (GreenEarth), hydrocarbon, and glycol ether, can r elease 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 solve nts 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 wat er did not exhibit aquatic toxicity (IRTA, 2005).

In addition, IRTA and LACSD analyzed the wash and r inse effluents from four wet cleaning facilities for certain metals, toxic o rganics, and aquatic toxicity. None of the samples contained metal concentrations that exc eeded hazardous waste levels. Perc and/or trichloroethylene (TCE) were found in t he effluent from three of the wet cleaning facilities. In some cases, the concentrat ions of these toxics exceededVI -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 ma y have been entrained in garments cleaned in the wet cleaning machine. The analysis indicated that effluent samples from all four facilities did not exhibit aq uatic toxicity despite the presence of Perc and/or TCE. (IRTA, 2005)

B. Groundwater Contamination

One of the concerns with the use of Perc is groundw ater contamination. Perc is known to pass through porous surfaces, such as buil ding walls, sewer lines, and cement floors (ARB, 1993). Therefore, Perc usage p oses 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 lev els 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 per cent 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 enviro nmental 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-2000 TM Fluid (DF-2000) is released into the environment, volatil ization from water to the air is calculated to occur in a few days. Non-volatized p roduct in the natural environment will biodegrade at a moderate rate and not persist. (Ex xonMobil, 2003) Other high flash point hydrocarbon solvents are expected to behave s imilarly.

The GreenEarth solvent is unlikely to leach into gr oundwater because it is not very soluble in water and readily sticks to soil pa rticles (GreenEarth, 2003). Based on conclusive test data with other silicone materials, if spilled on the ground, Decamethylcyclopentasiloxane, or D 5 , 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 l ow solubility in water (<100 parts per billion (ppb)) and is very close in density to wate r; 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 bet ween 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 amou nts of GreenEarth solvent are kept in contact with soil, it will also be expected to deco mpose to carbon dioxide, silicon dioxide (sand), and water. (IFI, 2002)

Groundwater contamination is not a concern using t he CO 2 process. At room temperature, CO 2 can exist as a liquid if kept in a closed system a t an elevated pressure. The cleaning systems used for CO 2 are able to efficiently convert CO 2 from a gas to a liquid. One of these systems permits 98 p ercent of the CO 2 to be recycledVI -3

(U.S. EPA, 1999). In general, only a nominal amoun t of CO 2 is then vented to the atmosphere.

Environmental fate on the Rynex TM (Rynex 3) solvent is not readily available, but the Rynex 3 formulation is a type of propylene glyc ol ether. Proplylene glycol ethers are known to be biodegradable. All propylene glycol et hers 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 r apid biodegradation in soil. (SIDS, 2003)

C. Hazardous Waste

Hazardous waste is regulated in California by a fed erally authorized State program. Under this program, Perc is classified as hazardous waste. In California, all hazardous waste at a facility must be transported o ff-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 f ilters used to remove lint and insoluble soil from the extracted Perc. Cartridge filters ar e typically replaced every six months or less, depending on workload and manufacturer recomm endation. 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 rel atively small compared to Perc. In terms of waste volume, the CO 2 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 mentione d alternative processes include spent filters and still bottoms. The still bottoms from four dry cleaning facilities that used hydrocarbon, GreenEarth, Rynex 3 and CO 2 , were analyzed in a study IRTA conducted with LACSD. The results of these tests showed exce ss levels of lead for one of the still bottom samples and three out of four of the still b ottom samples exhibited aquatic toxicity (IRTA, 2005). Because none of the solvent s contain lead and are not expected to exhibit aquatic toxicity, the results indicate t hat the spotting chemicals and detergents used may alter the characteristics of the waste str eams. Alternately, waste streams from alternative processes can be handled as hazard ous 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 d etergents that are used areVI -4

biodegradable and designed for discharge via the sa nitary sewer. These detergents should be readily removed at the local treatment pl ant (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 Superf und sites in the country (CFCA, 2002). However, there is always concern of soil contamination in all dry cleaning processes. Soil contamination can occur t hrough accidental releases, such as spills, or during the distillation process from a b oil-over. Although federal, state, and local environmental regulations have been developed to help minimize soil contamination, dry cleaners should take all necessa ry steps to contain spills and clean them up quickly.

E. Flammability

Flammable and combustible liquids are listed in dif ferent classes. The combustible liquids used in the dry cleaning indust ry 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 combus tible liquids may require the issuance of fire permits. Class II liquids, like the Stodda rd 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 liqu ids, 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 fi re hazards. (JE, 2004)

Stoddard has been a popular dry cleaning solvent th at saw a significant usage
decrease based on fire hazard concerns. As mention ed 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 solven ts 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 Occupa tional Safety and Health Act (CAL/OSHA) standards because they are classified as combustible liquids. This group
of solvents includes DF-2000 TM 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 u sed in the garment industry today. They are GreenEarth, Rynex 3, and CO 2 . 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. Ryn ex 3, which has a flash point greater than 200 ° F, is classified as a Class IIIB liquid which is al so considered a combustible liquid. (JE, 2004) Based on a study c onducted by the North CarolinaVI -5

Department of Environment and Natural Resources, CO 2 is a weak solvent; therefore, a detergent mixture is used as a supplement to the ba se 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 CO 2 /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 t hat are not considered a fire hazard. Therefore, there is no potential flam mability risk involved with these processes. For comparison purposes, Table VI-1 bel ow gives you a summary of the flash points and classifications of the commonly us ed solvents in the dry cleaning industry.

Table VI-1. Summary of Flash Points and Classifica tion for Commonly Used Solvents 1

Solvent Flash Point Classification

Perc N/A IV
Stoddard 110 ° F II

DF-2000 147 ° F IIIA
PureDry 2 350 ° F IIIB/IIIA

Shell 140 >143 ° F IIIA

EcoSolv >140 ° F IIIA
Rynex 3 >200 ° F IIIB

GreenEarth 3 170 ° F IIIA

CO 2 4 N/A N/A

1. Source: Material Safety Data Sheet, unless othe rwise 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 so lvent. 3. Source: Cleaners Family , Volume 4. 4. The detergent mixture used as a supplement with the CO 2 solvent is a hydrocarbon and is classified as a II IA solvent, but when used together with the CO 2 it is not considered a fire hazard.

F. Energy Usage

According to a report prepared by Jacobs Engineerin g 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-bas ed technologies, tests conducted by the Pollution Prevention Education and Research Center (PPERC) at a facility that switched from Perc to professional wet cleaning fou nd a reduction in electricity use (to approximately 600 kWh per month). The CO 2 system requires a 70 to 150-amp service to operate the refrigeration system necessary to ma intain the CO 2 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 technologie s and it could result in increased peak load demand charges. Therefore, the assumption is made that a CO 2 shop will utilizeVI -6

30 percent more power than a shop using Perc. Base d on available information, Table VI-2 shows monthly energy usage for Perc dry cleaning and alternatives. (JE, 2004)

Table VI-2. Estimated Monthly Electricity Usage 1

Process Electricity Usage (kWh)

Perc 1,100
DF-2000 1,100
GreenEarth 1,100 Wet Cleaning 600
CO 2 1,430

1. Source: JE, 2004.

Chapter VII gives additional information on electr icity 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 require s a mix of ozone-forming chemicals, also known as volatile organic compounds (VOCs), nitrogen oxides, oxygen, and sunlight. Any reduction in VOC emissions is ex pected to provide a beneficial environmental impact on air quality by reducing tro pospheric ozone formation. The hydrocarbon solvents and the Rynex 3 solvent are cl assified as VOCs. An increase in the usage of these solvents may cause an environmen tal 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 V OCs Statewide.

Greenhouse gases alter the amount of heat, or infr ared 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 CO 2 has been the traditional focus of greenhouse gas concerns, the CO 2 used in the dry cleaning process is an industrial b y-product from other industrial operations and does not contribute to global warming. In the United States, the largest source of greenhouse gas emissi ons is from fossil fuel combustion, which accounted for approximately 81 percent of gre enhouse 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 es tablished 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 hasVI -7

a PEL of 25 parts per million (ppm) and Stoddard ha s a PEL of 100 ppm. Although the remaining solvents do not have PELs, Table VI-3 giv es 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 throat 1 Unknown 100 ppm

DF-2000 central nervous system; irritation to

eyes, skin, and respiratory tract 2 unknown N/A

PureDry central nervous system; irritation to

eyes, skin, nose, throat, and respiratory tract 2 unknown N/A

EcoSolv central nervous system; irritation to

eyes, skin, and respiratory tract 2 unknown N/A

Shell 140 central nervous system; irritation to

skin, nose, throat, and respiratory

tract 2 unknown N/A

GreenEarth (D 5 ) mild eye irritation increase in liver weight 3 N/A Rynex 3 headaches; irritation to eyes, nose,
and throat 1 unknown N/A

CO 2 irritation to skin and eyes, 4 frostbite 5 unknown N/A

1. Source: U.S. EPA, 1998. 2. Information taken from Material Safety Data Shee ts. 3. See Appendix G. 4. Due to exposure to detergents used with the CO 2 process. 5. Due to exposure to liquid CO 2

.VII - 1



### VII. COST ESTIMATION

The data used in the cost analysis of the various d ry cleaning processes was based on information collected from equipment manuf acturers and distributors as well as from publicly available information. The catego ries covered in this analysis include estimates on the cost of machines, operation, insta llation, leak detectors, and control technology.

A. Machine Cost

Estimated machine costs are based on the Machine Ma nufacturers Survey and are presented in Table VII-1. As there are a varie ty of sizes and models that affect the actual price of each machine, costs are given in ra nges for each technology.

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

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

CO 2 4 Dry-to-Dry 60 35-40 140,000

1. From Machine Manufacturers Survey, unless otherw ise noted. 2. This reflects manufacture list price, machines c an cost less. Also, does not include installation costs. 3. This does not include the annual GreenEarth “Aff iliation Fee.” 4. Source: ARB, 2005c.

Professional wet cleaning (wet cleaning) systems co nsist of a separate washer and dryer and require tensioning equipment. The tw o most common tensioning equipment pieces used are the form finisher, with a n 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 need s 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 founda tion and are not suitable forVII - 2

upper-floor or above-basement installations (PPERC, 2004). According to the Machine Manufacturers Survey a 35-pound soft mount washer i s approximately $15,100 whereas a 40-pound hard mount washer is about $14,2 00. The cost of a wet cleaning dryer with a 50-pound capacity is estimated at $4,5 00. Dry cleaners can expect to pay between $39,600 and $40,500 for a “typical” wet cle aning system (including tensioning equipment). Costs will be higher if a larger capac ity 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 m inimize shrinkage (as well as wrinkles) at the end of the cleaning cycle.

The GreenEarth  (GreenEarth) dry cleaning machines with the capaci ty range of 35-pounds to 90-pounds are list priced at $43,000 t o $98,000 according to the Machine Manufacturers Survey. There is also an annual Gree nEarth “Affiliation Fee” of $2,500 per machine. If a facility has more than one machi ne, there is an annual “Affiliation Fee” of $1,250 for each additional machine. (ARB, 2005d )

According to the Dry Cleaning Facility Survey (Faci lity 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 w ith an alternative dry cleaning machine, it would typically be replaced with a slig htly larger machine. Table VII-2 gives a cost comparison of Perc secondary control machine s and the alternatives, including hydrocarbon, GreenEarth, water-based cleaning, and carbon dioxide (CO 2 ).

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 chill er or water tower included in the installation. If this were the case, the installat ion cost would range from $3,000 to $5,000. The installation cost for a hydrocarbon ma chine and a GreenEarth machine is basically the same. The installation cost range fo r these two types of machines is $5,000 to $6,000. The current installation cost fo r a CO 2 machine with a chiller is $50,000. As for wet cleaning, the installation cos t for a complete wet cleaning process will range from $2,000 to 2,500. If a facility own er 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 relocat e 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 li nes and traps. (ARB, 2004a; ARB, 2004b; ARB, 2005c)VII - 3 Table VII-2. Machine Cost Comparison for a Typical Dry Cleaning Facility 1

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 $61,00 0 +$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 Cleaning 4 (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
CO 2 (60-lb capacity) 5 $50,000 $140,000 +$96,100

1. Based on information from ARB’s 2004 Machine Man ufacturers survey, unless otherwise noted. 2. The cost estimates given for the soft and hard m ount wet cleaning system are for washer/dryer combi nation. 3. This does not include the GreenEarth annual affi liation fee of $2,500 for the first machine purchas ed 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 t he garment cleaning industry. The operating costs will vary according to the clea ning process. The most important operating cost variables include solvent cost, dete rgent 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 mai ntenance cost may include cleaning of traps and still, draining and cleaning the separator, cleaning and changing filters, lubricating machine parts, checking pressu re level, and changing carbon filters.

Solvent costs will vary according to the dry cleani ng technology used. The hydrocarbon technology has a variety of alternative solvents available. The most commonly used alternative solvent is DF-2000 TM Fluid (DF-2000). Table VII-3 gives an
overview of the available solvents and what the cur rent cost is to the industry. Perc solvent costs given on this table include the curre nt $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 use d as the solvent; therefore, there can be a change in water usage when switching to wet cl eaning. A study conducted by Pollution Prevention Education and Research Center (PPERC) showed that there couldVII - 4

be a 17 percent increase in water usage after switc hing to wet cleaning. This amounted to a $4 per month increase for water usage.

Table VII-3. Dry Cleaning Solvent Costs 1

Solvent Cost Perc $19/gal. Hydrocarbon
DF-2000 2 $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. Rynex TM (Rynex 3) $20/gal.
CO 2 4 $0.12-0.25/lb Green Jet $12.80/gal.

1. There is no solvent cost for Professional Wet Cl eaning. The cost impact for this technology would be in an increase of wate r 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 c osts 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 us ed to normalize the annual operating costs of each process for a typical facility.

According to the Facility Survey, it is estimated t hat a Perc dry cleaning facility uses about ten standard filters each year and the r emaining alternatives, with the exception of CO 2 and Green Jet, use about seven standard filters eac h year. Standard filters were used for the cost comparison because t his 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 r equire a spin disk filter which will incur an additional cost of $90 for each filter (PPERC, 2 002). The CO 2 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 filt er bag, foam filters, and felts which can be cleaned and reused. Since this system is re latively new, the lifespan of the felts
and filters is unknown and it is difficult to estim ate annual replacement costs. However, if these components were to be replaced, the cost w ould be $100 for the filter bag, $20 for the foam filters and $4 for the set of eight fe lts.

Table VII-4 list the average therm and kilowatt hou r (kWh) usage per dry cleaning machine for each process. Information gathered fro m 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 PP ERC. Cost estimates for gas usages were made using the July 2005 Pacific Gas an d Electric (PG&E) rates of $1.21 for summer months (April 1 through October 31) and $1.25 for winter monthsVII - 5

(November 1 through December 31). The 2005 Sacrame nto Municipal Utility District (SMUD) average rate of $0.10 per kWh was used to es timate electricity usage. Calculations used to estimate electrical cost can b e found in Appendix J.

Table VII-4. Average Machine Gas and Electricity Us age

for Each Dry Cleaning Process

Machine Type Therm Usage/Month 1 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
CO 2 156 9.3 - 9.7
Green Jet 2 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 optio n 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 facilit y 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 r eplaced 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 addit ional operating cost for disposal. Waste disposal costs for each of the technologies w ere 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 Facili ty 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. T he machine cost values in Table VII-5 are based on a five year loan with a ten percent in terest rate. Therefore, the values for
the total annual costs on the table reflect the cos t of the first five years of operation. For years six through the life of the machine, the tota l annual cost would not include a
machine cost. The numbers in Table VII-5 are round ed to the nearest dollar value.VII-6Table VII-5. Annual Cost Comparison for the FirstFive Yearsof a Typical Size Dry Cleaning Facility11. Where applicable, costs are normalized to about46,600 pounds of clothes dry cleaned per year for atypical facility. Additionally, costs are roundedto the nearest value.2. 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 same as DF-2000.3. 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 spin disk.5. 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 pergallon (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 CO2machine 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 cleaningto 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 $20 for the foam filters.17. It is important to note that the total operating cost shown for the Green Jet technology will increase because gas costs are unknown.Technology SolventAverage CostDetergent/SpottingAgentsElectricityCostGas Cost2AverageMaintenance3AffiliationFeeFilters4Cost toReplaceGasketsMachineCost5WasteDisposal($/gal.)6Total AnnualCost7Perc $1,1598$1,500 $850 $7,800 $375 N/A $320 $500 $12,372 $2,500 $27,376Hydrocarbon:DF-2000 $546 $1,500 $850 $3,580 $250 N/A $371 $500 $17,674 $2,640 $27,911PureDry $1,170 $1,500 $850 $3,580 $250 N/A $371$500 $17,674 $2,640 $28,535Shell 140 $390 $1,500 $850 $3,580 $250 N/A $371$500 $17,674 $2,640 $27,755EcoSolv $507 $1,500 $850 $3,580 $250 N/A $371 $500 $17,674 $2,640 $27,872StoddardSolvent$283 $1,500 $1,1609$3,580 $600 N/A $371 $500 $17,674 $2,640 $28,308GreenEarth $1,715 $1,10010$850 $4,370 $850 $2,500 $371 $500 $18,202 $2,26011$32,718Rynex 3 $1,000 $100 (spottingagents only)$850 $3,580 $625 N/A $371 $500 $17,674 $12012$26,220CO2$552 $1,500 $940 $2,290 $2,250 N/A $23813$500 $50,121 $490 $58,881ProfessionalWet Cleaning$0-$4814$2,35515(detergent/conditioner only)$660(washer/dryer)$5,700 $32015N/A N/A $500 $11,343 N/A $20,926Green Jet $1,152 $1,500 $600 Unknown $400 N/A $12416N/A $8,573 N/A >$12,34917VII - 7

C. Leak Detector Cost

Most dry cleaners currently use a halogenated-hydro carbon detector made by
TIF TM Instruments, Inc. (TIF) to check for vapor leaks. The cost of these detectors range from $170 to $250 depending on the model. After co nducting a comparison of available detectors on the market, we found that there are de tectors that may be able to give a more accurate reading of Perc concentration. The m ore 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 ar e comparable to the detectors presently used by the dry cleaning operators, but u se 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-M ate detectors that are comparable in cost to the TIF detectors. These gas sensors ra nge 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 Concentra tion Detectors

Product List Price

TIFXL-1A 1 $ 170 TIF 8800 Combustible Gas Detector $ 210 TIF 8800A Combustible Gas Detector $ 240

TIFRX-1A 1 $ 240

TIF 5750A 1 $ 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 $1,600 2

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 5050 A 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 measu ring chip needed after ten leak checks.

D. Control Technology

There are several control options for the dry clean ing industry. Both Perc and hydrocarbon machines can be purchased with a second ary 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 secon dary control machine is $43,000.VII - 8

Secondary control can be added to an existing machi ne 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, 20 04b). Spin disks are also used as secondary control and can also be added on to a mac hine. The 1998 and newer machines are equipped with convertible filters, whi ch means that the housing can be changed from cartridge to spin disk. The cost f or this would be under $1,000, but for machines older than 1998 it would most likely be mo re (ARB, 2004b).

Some local air districts require dry cleaning facil ities to install room enclosures with ventilation systems. In a July 2000 report pr epared by ATC Associates, Inc. (AVES) for the ARB, costs associated with room encl osures were identified. There are three different types of enclosure/ventilation syst ems: vapor barrier rooms (VBRs), partial vapor barrier rooms (PVRs), and local venti lation systems (LOCs). The capital costs between the three different types vary accord ing 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-al one structure. Cost of construction will vary due to dry cleaner’s needs and local air distr ict requirements. Construction may include walls or the installation of a blower, exha ust 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 PV R would cost about $4,800, and the LOC would be about $3,100 to $4,300. (AVES, 200 0; BLS, 2004)VIII -1



### VIII. EFFICACY EVALUATION

Efficacy, or the ability to effectively clean clot hes, is an important factor to consider when considering dry cleaning alternatives . Properties to consider include: cleaning ability, evaporation rate, and ease of pur ification through distillation. The solvent should not cause fabric to unnecessarily fa de, shrink, weaken, or bleed color, and should be compatible with detergents.

The overall cleaning ability of a process depends o n soil chemistry, textile fabric type, transport medium (aqueous vs. non-aqueous), c hemistry of the additives (detergents, surfactants), the use of spotting agen ts, and process considerations (e.g., time, temperature, and mechanical actions) (U.S. EP A, 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 clean ing 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 usua lly 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 al ternatives.

A. Hydrocarbon Solvent Cleaning

Typically, solvents are more effective in cleaning oil stains, and
water-based chemicals are more effective in cleanin g sugar, salt, and perspiration stains. The cleaning process can be enhanced with the use of spotting agents, alternative detergents, surfactant additives, and o ther 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-2000 TM 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 hav e reported that fabrics come out fresher with no odor and that they could clean a wi de range of items. Some operators have complained that clothes feel oily; however, th at 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, 2 004)

PureDry is a blend of isoparaffinic hydrocarbon with a chem ical additive produced by 3M. Efficacy testing for PureDry was done at Wa lt Disney World Textile Services. The clothes were cleaned to exceptional standards a nd without residual solvent odor in the finished garment (JE, 2004).VIII -2

B. Rynex TM

The Air Resources Board (ARB) staff was not able to locate any independent efficacy testing for Rynex TM (Rynex 3). However, the manufacturer claims that Rynex 3 is a superior, gentle cleaner (when compared to Per c) 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 propert ies 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 solv ents (Rynex, 2005). These claims, however, have not been verified with independent te sting.

C. Water-based Cleaning Systems

Several tests have been conducted on water-based cl eaning systems. In 1999, the Pollution Prevention Education and Research Cen ter (PPERC) published a study on the performance evaluation of a facility converting from Perc dry cleaning to Professional Wet Cleaning (wet cleaning). The perf ormance evaluation showed that over 99.5 percent of the garments that would have b een dry cleaned were able to be wet cleaned. Claims for ruined garments were the s ame for both Perc dry cleaning and wet cleaning. Although the rate for additional wor k (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 tra ining has a considerable impact on the reported efficacy of this technology.

In 2003, the PPERC published an assessment of the G reen Jet  (Green Jet) System. The assessment consisted of interviews and site visits with facility owners using Green Jet. Several advantages and disadvanta ges were identified. The shop owner indicated that the advantages of the system w ere that Green Jet did not require as much experience or skill as the hydrocarbon equi pment 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 s oiled garments could not be processed; and, 3) additional technology was required for garm ents 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 t he full range of textiles, particularly in situations where heavily-soiled gar ments need to be processed. (PPERC, 2003)

D. Carbon Dioxide Cleaning

Although ARB staff was not able to locate any indep endent efficacy testing on CO 2 cleaning, one CO 2 machine manufacturer performed testing that was pu blished by the United States Environmental Protection Agency’s (U.S. EPA) Design for the Environment. Design for the Environment is a coope rative project between U.S. EPA and the garment and textile care industry garment a nd textile care partnership. One advantage, according to the manufacturer, is that t he color retention can meet orVIII -3

exceed that of Perc dry cleaning. One exception to this is certain triacetate and acetate fabrics with specific yellow dispersive dyes. Ther e was some shrinkage for garments that were triacetate-based only. However, these ga rments are quite rare. Triacetate based garments may be better handled by professiona l wet cleaning. (U.S. EPA, 1999)

E. GreenEarth 

The International Fabricare Institute (IFI) conduct ed testing on the efficacy of
GreenEarth  (GreenEarth) solvent under a contract to GreenEart h (IFI, 2002). This solvent contains decamethylcyclopentasiloxane (D 5 ), which is the primary cleaning agent in GreenEarth. GreenEarth was ranked in seve ral different categories including: cleaning performance, the ability to ha ndle garments that dry cleaners currently process, affordability, capital costs, he alth issues, and contamination issues.

Based on the testing, IFI concluded that stain remo val 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 p oint ink, vegetable oil, and shoe polish. Overall, IFI found that GreenEarth cleaning is a vi able 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.
CO 2 <10 1 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 temperat ure 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 Perchloroethylen e 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 Per chloroethylene Dry Cleaning Operations, California Air Resources Board, August 27, 1993.

ARB, 1996. Curriculum for the Environmental Traini ng Program for Perchloroethylene Dry Cleaning Operations , California Air Resources Board, April 1996.

ARB, 1997. Toxic Air Contaminant Identification Li st – 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 Phill ips 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, Chev ron Philips Chemical Company to Mei Fong, ARB, January 2004.

ARB, 2004f. Feori Wet Cleaning System brochure fro m Future Clean U.S.A.

ARB, 2004g. Resolve Drycleaning System company pre sentation, 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 Techniche m 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 Sol vent Questions and Answers (2652) , 2004. Website at http://www.lyondell.com/html/pro ducts/techlit/2652.pdf

ARB, 2005g. Telephone Conversation with Bob Blackb urn, October 18, 2005.

AVES, 2000. The Assessment of the Effectiveness of Room Enclosures with Ventilation Systems in Reducing Risk at Dry Cleanin g Facilities Using Perchloroethylene. AVES, an Affiliated of ATC Associates Inc., July 14, 2000.

Begley, 2004. E-mail from Reg Begley, Sail Star, O ctober 20, 2004.

BLS, 2004. Bureau of Labor Statistics, U.S. Depart ment of Labor, Consumer Price Index, 2004.

CDHS, 2003. California Department of Health Servic es (CDHS), 2003 Health Hazard Alert, Hazard Evaluation System and Information Sys tem, 1-Bromopropane, July 2003.

CFCA, 2002. Coalition for Clean Air, Hung Out to D ry: 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 reg arding California Dry Cleaning Industry Technical Assessment Rport. November 22, 2005.

Cleaners Family, 2004. Cleaners Family, Miracle So lvents? Evaluation of Hydrocarbon, GreenEarth, PureDry vs Perc; The Secrete of the Am azing Cleaning Results by
Alternative Solvents , Volume 4, No. 1, February 2004.

ExxonMobil, 2003. Product Environmental Profile, D F-2000 TM Fluid, ExxonMobile Chemical, January 9, 2003.IX-3

GreenEarth, 2003. Memo from Jim Barry, Chairman of GreenEarth Cleaning to Affiliates, Friends and Associates regarding GreenE arth 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 Technol ogies for Textile Cleaning

, Institute for Research and Technical Assistance, Au gust 2005.

JE, 2004. Viable Alternatives to Perchloroethylene in Dry Cleaning , Jacobs Engineering, Prepared for City of Los Angeles, Dece mber 30, 2004.

JOEH, 2005. A Proposed Methodology for Setting Occ upational 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), Stodd ard (1997), PureDry (2002), Shell 140 (1992), DF-2000 (2000), and EcoSolv (2003).

NC, 2001. Alternatives to the Predominant Dry Clea ning Processes , North Carolina Department of Environment and Natural Resources, Oc tober 2001.

NTP, 2004. NTP Technical Report on the Toxicology and Carcinogenesis Studies of
Stoddard Solvent IIC In F344/N Rats and B6C3F 1 Mice, National Toxicology Program. September, 2004.

OEHHA, 2003. Memo from George Alexeeff to Peter Ve nturini regarding health effects of exposure to alternative dry cleaning solvents, D ecember 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 Cente r, October 28, 2002.

PPERC, 2003. Memorandum, Subject: Current Assessm ent of Green Jet Garment Cleaning System, Pollution Prevention Education and Research Center, April 11, 2003.IX-4

PPERC, 2004. Professional Wet Cleaning Equipment R eport , 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 Solu tions Website, www.rynex.com

.

Rynex 2005a. The Facts about Rynex the Proven Alte rnative Solvent, www.rynex.com

SIDS, 2003. SIDS Initial Assessment Report For SIA M 17 , November 2003.

Smerling, 2004. Telephone conversation with Bob Sm erling, October 29, 2004.

SMUD, 2005. General Service Rate Schedules , Sacramento Municipal Utility District, March 3, 2005.

South Coast, 2002. Final Staff Report - Proposed A mendment Rule 1421 - Control of Perchloroethylene Emissions from Dry Cleaning Syste ms , South Coast Air Quality Management District, October, 2002.

U.S. EPA, 1998. Cleaner Technologies Substitutes A ssessment: Professional
Fabricare Processes . Design for the Environment, June 1998.

U.S. EPA, 1999. Case Study: Liquid Carbon Dioxide (CO 2 ) Surfactant System for
Garment Care , Design for the Environment. www.epa.gov/opptintr/dfe/pubs/garment/lcds/micell.h tm . May 1999.

U.S. EPA, 2003. Siloxane D5 in Drycleaning Applica tions , Fact Sheet, August 2003.

### Appendix A

Dry Cleaning Facility SurveyWinston H. Hickox Agency Secretary

The energy challenge facing California is real. Ev ery Californian needs to take immediate action to r educe 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, Califor nia 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 gove rnment agencies. We are asking each dry cleaning facility to complete and return the enclos ed Survey.

The Survey has two parts. Part 1 of the Survey req uests general information about your dry cleaning business. Part 2 of the Survey reques ts 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 enclo sed postage paid envelope by October 10, 2003 at the address shown below:

Attention SSD Dry Cleaning Surve y 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 En glish 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 C ompany 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 thi s survey?

The ARB is currently conducting a statewide assessm ent of the California dry cleaning industry. The purpose of the assessment is to impr ove our understanding of the various technologies being used in the dry cleaning industr y and to collect information regarding cost, efficacy, and environmental impact of those t echnologies. The enclosed survey is anA- 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 t o 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 a ffect 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 accu rate as the information you provide.

Does the ARB have the legal authority to request th e information on the Survey?

Yes. State law (Health and Safety Code, section 39 660) authorizes the ARB to request and gather information needed to evaluate toxic air contaminants, such as perchloroethylene (Perc), and other substances. Th e 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 wi ll automatically be entered into a drawing
for one of five FREE environmental training classes.

Thank you in advance for your assistance in providi ng us this information. If you have any questions or comments, please do not hesitate to co ntact 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 SectionWinston H. Hickox Agency Secretary

The energy challenge facing California is real. Ev ery Californian needs to take immediate action to r educe energy consumption. For a list of simple ways you can reduce demand and cut y our 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, Califor nia 95812 • www.arb.ca.gov Gray Davis Governor

September 12, 2003

드라이 크리닝업 종사자 분들께 :

대기자원 관리국 ( ARB )에서는 , 켈리포니아주 세탁협회 , 한인 드라이 크리너

세탁협회 , 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 세부 적인 질문입니다 . 만약 세탁기게를 하나 이상 소유하고 계실경우

,

질문서의 두번째 부분을 복사하여 각 세탁기계당 하나씩 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

. ARB 는 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 1 번 업소조사 란에 답하신 후

, 두번째 페이지 6 번 기타사항 란에 “ 드라이 크리닝을하지않음 .” 이라고 쓰신 후에 제출하여주시기를 부탁드립니다

.
대기자원관리국에서 나의 도움이 필요한 이유는 무엇입니까 ?

ARB 는 현제 켈리포니아 드라이 크리닝업소를 평가하려합니다 . 이번 평가의 목적은 , 드라이 크리닝업소에서 사용하는 기술에대한 저희의 이해를높이고 또, 그런 기술에 드는 비용과 효율성에대한 정보를 얻기위합입니다 . 동봉한 질문서는 이번A-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 . 대기자원관리국 은 펄크 ( Perc ) 를 유해한 대기오염물질로 1991년 10월에 지정하였읍니다

. 이 질문서는 언제까지 제출하여야 합니까 ?

October 10, 2003 까지보내 주시기를 바랍니다 . 날짜안에 제출하 여 주시는것에 대한 감사의 뜻에서 , 제출 하신분 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 DivisionA-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 SectionQUESTIONS AND ASSISTANCE

Hafizur Chowdhury Sonia V illalobos Mei Fong Phone: (916) 322-2275 Phone: (916) 327-5983 Phone: (916) 324-2570 E-mail: hchowdhu@arb.ca.gov E-mail: svil lalo@arb.ca.gov E-mail: sfong@arb.ca.gov

Please return the completed survey by October 10, 2 003 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 [ ] I f no, please provide contact information of the dry cleaning facility you send your

clothes to in number 6 (comments area on page 2) an d return the survey to us.

How many total dry cleaning machines are in the fac ility? 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, 2 003, you will automatically be entered into a drawi ng 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 provi ded under California law Thank you for taking the time to complete this surv ey. Please be advised that the survey has two part s (Part 1 and Part 2) and your response on both parts is appreciated. If you have any questions about the dry cleaning faci lity survey or need assistance in completing the survey, please feel fr ee to contact any of the following staff:

Less than $100,000 [ ] $100,001 - $500,000 [ ] $500,001 - above [ ]

Full Time ______ Part Time ______ Average Part Ti me 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 se parator 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 CO 2 [ ] 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 ____________________________________ Ph one (_____)________________

Company name ____________________________________ Pho ne (_____)________________

Who collects your waste (e.g., still bottoms, separ ator 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 fa cility (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 fum e/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 [ ] St oddard [ ] Green Earth [ ] Liquid CO 2 [ ] 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 4What 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 (pound s) 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 CO 2

______ ______ ______ 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) 200 0 ______ 2001 ______ 2002 ______

(c) Jumbo (13-inch diameter, 18 inches high) 20 00 ______ 2001 ______ 2002 ______

(2) Spin-Disk

Non-Powdered [ ] Powdered [ ]

How often do you inspect the machine?

Daily [ ] Weekly [ ] Monthly [ ] Bi-monthl y [ ] Quarterly [ ] Twice a year [ ] Yearl y [ ] 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 Additio nal Machine 

### PART 2

Survey 2003 A-9 PART 2 - Page 1 of 1문의사항과 도움

Hafizur Chowdhury Sonia V illalobos Mei Fong Phone: (916) 322-2275 Phone: (916) 327-5983 Phone: (916) 324-2570 E-mail: hchowdhu@arb.ca.gov E-mail: svil lalo@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: 업체 종류: 공장/소매 [ ] 산업체 [ ] 관영 [ ] 비영리법인 [ ] 호텔/모텔 [ ] 기타 [ ]

( )

$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: 업체소유형태: 개인소유 [ ] 체인형태 소유 [ ] 푸렌차이스 [ ] 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 CO 2 [ ] 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 CO 2 [ ] 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 2몇년도에 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 CO 2

______ ______ ______ 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 SurveyFacility 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 lo cated? _____________________

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 ________ fee t

Back Door height ________ feet, width ________ feet

Window height ________ feet, width ________ feet Amount of annual receipt (dollar) from total operat ion ___________________ 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 3DRY CLEANING SITE VISIT SURVEY 2003

Is the facility a part of a larger building? ______ __________ Stand alone building? ________

Dimension of the building: Length ______ feet Wid th _______ feet Height _______ feet

Does the facility have a stack? ______

Stack height ______ feet Stack diameter ______ fee t

Does the stack has a raincap/horizontal release? __ ___ Stack airflow ______ cfm

Does each machine have separate stacks or do they c ombine into single stack? ______

Distance measured from door to door:

Nearest business _____________ feet Resi dence ______________ feet

Nearest (School/Day Care/Hospital/Park/Senior Commu nity) _______________________ feet

What type of fan(s) do you have in your facility? _

__________________________ Is there a vapor barrier (room enclosure) around th e 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? (wri te 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 l oads per week ______

Total amount of clothes dry cleaned per year (pound s) 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 3DRY CLEANING SITE VISIT SURVEY 2003

How much still bottoms (gallons) removed in year 20 00 ______ 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 filte rs? ______________________________

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 SurveyQUESTIONS AND ASSISTANCE

Hafizur Chowdhury Sonia V illalobos Mei Fong Phone: (916) 322-2275 Phone: (916) 327-5983 Phone: (916) 324-2570 E-mail: hchowdhu@arb.ca.gov E-mail: svil lalo@arb.ca.gov E-mail: sfong@arb.ca.gov

Please return the completed survey by April 30, 200 4 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 s heet as an attachment if necessary.



### MACHINE MANUFACTURER SURVEY

( ) Thank you for taking the time to complete this surv ey. If you have any questions about the manufactur er survey or need assistance in completing the survey, please feel fr ee to contact any of the following staff:

Specify types of machine (for example: Dry-to-dry p rimary control, Dry-to-dry secondary control, Trans fer, Wet Cleaning - Washer, Wet Cleaning - Dryer, or others)

.

Specify gas or steam requirements to operate the ma chine (for example: average monthly cost ($US) of g as or steam generation). Instruction: The description of each item on page 2 and page 3 are elaborated below to complete the survey accura tely:

Specify the solvent types for each machine brand (f or example: perc, DF-2000 TM , Rynex ® , Stoddard TM , Green

Earth ® , Water (wet cleaning), Green Jet TM , Pure Dry ® , Eco Solve TM , Liquid CO 2 or others).

Specify each machine brand (for example: Bowe Perma c, 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 machi ne 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 mo del stated in column 10 of page 2.

Provide the maintance requirements for each model a s stated in page 3 (for example: daily, weekly, mon thly etc.).

Specify the type of control equipment for each mode l.

MachineSurvey 2003 C-1 Page 1 of 4SolventaTypeMachinebBrandMachinecTypes ModeldRatedeCapacity(lbs)CyclefTime(minutes)ListgMachinePrice ($)ElectricalhRequirementGas/SteamiRequirementYearlyjMaintenanceCost ($).MACHINE MANUFACTURER SURVEYMachineSurvey 2003C-2Page 2 of 4ModeldEvery 4thLoad Daily Weekly MonthlyEvery 3MonthsEvery 6MonthsEvery 12MonthsOthern____ Othern____Othern____ Othern____Othern____Othern____ Othern____.Maintenance RequirementskControllEquipmentsShort Description ofEquipmentOperationmMACHINE MANUFACTURER SURVEYMachineSurvey 2003C-3Page 3 of 4COMMENTS 

### 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 - FIDD-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 c onstitute endorsement or recommendation of this product by the Air Resources Board. Specific brand names and instrument descriptions listed in the Standard Oper ating 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 m odifications to analyze perchloroethylene from dry cleaning sludge.

This method is suitable for the determination of th e exempt compounds: ethanol (AP/DO only), acetone, methyl acetate and tetrachlo roethylene (perchloroethylene). Additional analytes are metha nol, isopropanol, 1-propanol, isobutanol, and limonene.

2 SUMMARY OF METHOD

The dry cleaning sludge samples from each machine i s 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 tetrachloroeth ylene concentration. The samples of dry cleaning sludge are prepared as 1:10 wt. / volume dilutions in 1- methoxy-2-propanol (MPA). After dilution and thoro ugh mixing, the insoluble material is allowed to settle out, or the sample fi ltered to remove insoluble material. The diluted sample is then analyzed on a gas chroma tograph equipped with a flame ionization detector(FID). The data is report ed as percent perchloroethylene in the dry cleaning sludge.

3 INTERFERENCES AND LIMITATIONS

With the potential increase in the number of interf ering compounds, overlap of perchloroethylene’s retention time may occur. Care must be taken to make certain of the identity of the compound, if possible throug h 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 

### μ m 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 minJanuary 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 @ 35 o C 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 d ilutions,

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 coni cal 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, spectrophotometr ic 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 s tock solution is prepared

using acetone in MPA. The analyte is weighed in th e 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 equ ivalent.

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, st ir 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 sur e the sludge is remixed

between each sampling.

6.1.6 Place the triplicate samples in a travel cont ainer (such as an ice chest) at

ambient temperature for transport back to the labor atory.

6.2 Sample Preparation:

6.2.1 The collected samples are given a unique iden tification 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-D ickinson 15 ml) on a top

loading balance.

6.2.3.2 For the determination of water density as a control check, fill the conicalJanuary 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 int o 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 spre adsheet. The density is

calculated as weight per 16 mls and recorded in g/m l.

6.2.3.9 The tubes should be disposed in the hazardo us waste container.

6.2.4 Tetrachloroethylene Determination:

6.2.4.1 Weigh a one (1) milliliter aliquot of sludg e 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 autoinjecto r 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 genera tor 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 filli ng 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 calib ration 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 G C vial and cap.

6.4.4 Control/Check: Prepare the control/check by d iluting 1.0 mL of the

control/check stock standard to 10 mL with MPA. Th e control is analyzed
after the calibration. The check is run after ever y 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 followi ng order: MPA blank,

calibration standards, control/check, and diluted s amples. The check standard is run every tenth sample and at the end o f 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 S ection 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 tha n 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 prese nt 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 c ontrol limits, it may be necessary to recalibrate and rerun the sequence.

7.4 A check sample is run after every ten samples a nd 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 th at follow until the next
check.

8 CALCULATIONS

The weight fraction of analyte in the product is ca lculated as follows:



## ( ) ( ) 

## 10 2
g dilution sample mL

/ mg analyte Analyte of Fraction Weight − ×        

=

### Appendix E

Standard Operating Procedure
For the Determination of DF2000 TM 

### in Dry Cleaning Sludge by Gas Chromatography – Mass Selective DetectorE-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 c onstitute endorsement or recommendation of this product by the Air Resources Board. Specific brand names and instrument descriptions listed in the Standard Oper ating 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 DF2000 TM . DF2000 TM is a complex mixture of C11-C13 isoparaffinic hydrocarbons containing a low percentage of cyclopa raffins.

This method is suitable for the determination of al iphatic hydrocarbons in the range of decane (C10) to octadecane (C18) with boiling po ints ranging from 174 to 316 degrees centigrade.

2 SUMMARY OF METHOD

The dry cleaning sludge samples are collected in tr iplicate in a 250 milliliter (ml) glass jar. One aliquot is used to determine sample density and another aliquot is
used to determine DF2000 TM concentration. The samples of dry cleaning sludge a re prepared as 1:20 wt. / volume dilutions in methylen e chloride (MeCl 2 ). After dilution and thorough mixing, the insoluble materia l is allowed to settle out, or the sample filtered to remove insoluble material. The d iluted sample is then analyzed on a gas chromatograph equipped with a mass selecti ve detector (MSD). The data is reported as percent DF2000 TM in the dry cleaning sludge.

3 INTERFERENCES AND LIMITATIONS

Since the method looks for the generic class of hyd rocarbons from decane to
octadecane there is an increased likelihood of inte rference from hydrocarbon contribution from sources other than the sludge sam ple. Method blanks should be analyzed to insure the solvent and instrument are f ree of hydrocarbon
contaminants.

4 INSTRUMENTATION AND EQUIPMENT

4.1 Gas Chromatograph (GC) configured with a Mass S elective Detector (MSD),

4.1.1 GC Column: J & W DB-1, 60 m x 0.32 mm I.D. wi th 1.0 

### μ m 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 minMay 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 μ l, 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 d ilutions,

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 coni cal tubes,

4.5 Analytical Balance capable weighing to 0.1 mill igram,

4.6 Vortex Mixer, variable speed.

5 REAGENTS

5.1 Dichloromethane, Pesticide grade or better,

5.2 DF2000TM directly from the manufacturer or the d ry 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 bu ckets of dry cleaning sludge

which represents the total contents of the dry clea ning machine sump.

6.1.2 Using a long wooden or metal stirring rod, st ir 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 sur e the sludge is remixed

between each sampling.

6.1.6 If the aliquoted samples are not to be analyz ed 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 la boratory information

management system (LIMS) and given a unique identif ication number.

6.2.2 If the samples were stored in the refrigerato r 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-D ickinson 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 int o 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 spre adsheet. The density is

calculated as weight per 16 mls and recorded in g/m l.

6.2.3.9 The tubes should be disposed in the hazardo us 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 MeCl 2

.

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 a nalysis.

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 rang e.

6.2.4.5 Transfer an aliquot to a 1.8 ml autoinjecto r 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 cali bration is acceptable.

6.4 Analysis Preparation:

6.4.1 Solvent Blank: Prepare solvent blank by filli ng a GC vial with the same

MeCl 2 used to make the dilutions in steps 6.2.2 – 6.2.4. Cap the vial.

6.4.2 Calibration Standards: Prepare the five DF200 0TM 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 1.333May 24, 2005 E-6 Page 6 Bring to volume with MeCl 2 , mix thoroughly and place in dilution vials.

6.4.3 Transfer an aliquot of each standard into a G C vial and cap.

6.5 Sample Analysis:

6.5.1 Place vials in the autosampler in the followi ng order: MeCl 2 blank,

calibration standards, continuing calibration verif ication, and diluted samples. The continuing calibration verifcation st andard is run every tenth sample and at the end of the run. Additional blank s 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 S ection 8).

7 QUALITY CONTROL

7.1 An MeCl 2 solvent blank must be analyzed for each batch of s amples. The

analyte concentration in the blank must be less tha n 0.1 mg/ml. An MeCl 2 blank is run before the control and each check to p revent carry over from the previous sample.

7.2 The correlation coefficient for compounds prese nt 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) sam ple is run after every ten

samples and at the end of the run. The CCV must fa ll within +/- 25% of the
true value. If one of the CCV’s is out of the cont rol limits, re-run the CCV and any samples that follow until the next acceptable C CV.

8 QUANTIFICATION

8.1 Because DF2000TM is a complex mixture, seven (7) peaks are used to

represent the entire complex mixture during quantit ation. The peaks are identified as Peaks 1 through 7.

8.2 Peaks 1 through 7 are identified by retention t imes 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 avera ge of peaks 1 through 5, peaks

6 and 7, and peaks 1 through 7. 

## ( ) ( ) 

# 10 2 /

− ×        

= g

dilution sample mL mg analyte Analyte of Fraction Weight

### Appendix F

Sludge Sampling ResultsF-1 Table F-1. Perc Sludge Test Results (Primary Machin es)

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 0F-2 Table F-2. Perc Sludge Test Results (Secondary Mach ines)

Machine Test

No. Make Model
Year Sludge Density (g/ml) Sludge Density (lb/gal) %

solvent
in sludge # of

filter

Machine A,B 1 1 Columbia 1997 1.19 9.92 43 0 Machine A,B 1 2 Columbia 1997 1.21 10.09 51 0 Machine A,B 1 3 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 DetectorsAlan C. Lloyd, Ph.D.

Agency Secretary

The energy challenge facing California is real. Ev ery Californian needs to take immediate action to r educe 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 intend ed 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 facil ity at 1301 V Street in Sacramento. Results for this evaluation were reported to the Em issions Evaluation Section in an October 28, 2004 memorandum. However, the results are of questionable validity because they were produced using a non-traceable PE RC standard with an assumed concentration of 50 ppmv. STS has since procured c ertified, traceable dry calibration standards of 25 ppmv PERC, 50 ppmv PERC and 100 ppm v isobutylene. EES has also identified eight additional portable analyzers and presented them to STS for evaluation. The analyzers range in sophistication from semicond uctor sensors with audible alarms costing approximately $200.00 to photoionization de tectors with LCD displays costing in excess of $3,000.00. The ten analyzers and their r espective principles of operation are
identified in Table 1.

The h

⋅ nu Systems HW-101 was the designated reference anal yzer for this survey based on its availability and photoionization detector (P ID). The other PID analyzers used in the survey were available to EES on a temporary bas is. The HW-101 analog display is also motion sensitive, making it impractical for fi eld use as a leak detection tool. Although the HW-101 display is a relatively unsophi sticated analog potentiometer, itH-2

produced repeatable PERC concentration values in th e 0 – 200 ppmv range when calibrated against the 100 ppmv isobutylene standar d. HW-101 calibration was examined, and adjusted if necessary, before beginni ng 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 calibr ation standards contained in Tedlar bags. Gas was discharged by slowly depressi ng 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 approximat ion of the time necessary to attain the response. Standards were derived immediately p rior to analyzer evaluation by transferring 25 ppmv and 50 ppmv PERC calibration s tandards directly into dedicated 3 liter Tedlar bags from certified, traceable cylinde rs. The PERC concentration in each bag was then determined using the HW-101.H-3

Results for the portable VOC analyzer evaluations a re 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 appr oximate time needed for the analyzer to display a stable concentration. Theref ore, 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 wi th internal sample pumps (PhoCheck, MiniRae 2000) provide the best combination of accur acy and response time. Since PID analyzers are calibrated to isobutylene, its respon se to a PERC standard must be multiplied by a correction factor to obtain an equi valent 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 v ersus the calibration gases using a manufacturer supplied faceplate which channels cali bration gases directly to the detector. The faceplate is removed from the analyz er 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 t ime necessary for a diffusive analyzer to attain a stable response can be influen ced by the rate of discharge from the bag, meaning response time can be affected by the m agnitude of a leak.

A variety of results were observed for diffusive an alyzers incorporating semiconductor sensors. Analyzers producing an audible response, such as the tif – 5100 and Inficon Tek – Mate, demonstrated the ability to quickly det ect the PERC standard. However,
there is no discernible correlation between standar d concentration and the audible frequency produced by these instruments. The tif – 5100 can also be induced into registering a positive response by blowing air acro ss its sensor.

The Aeroqual Series 200 and Series 500 analyzers we re initially evaluated with the 25 ppmv and 50 ppmv PERC standards August 12, 2005. A t that time, the response from both analyzers to the calibration gases was a negat ive shift from the baseline concentration towards zero. Subsequent conversatio ns with Aeroqual staff revealed that Aeroqual PERC analyzers are designed for optim um 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 incre ases with decreasing RH. The calibration gases used by STS are dry (0% RH), expl aining the initial results. The Series 500 also displayed baseline concentrations o f 7 ppmv to 11 ppmv, compared to the zero to 2 ppmv baseline concentrations register ed by other analyzers. Replacing the Series 500 sensor head resulted in acceptable b aseline 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-1 01 indicates the humidifying process reduces the standard concentration by appro ximately one-third.

Exposing the Aeroqual analyzers to the humidified s tandards 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 analy zers.

The Drager Chip Measurement System (CMS) uses an in ternal pump to draw sample through a gas-specific, reagent filled, capillary c hip. The response times demonstrated by this analyzer (>100 sec.) indicate it is better suited for occupational safety applications rather than leak detection. This anal yzer appears to be especially sensitive to sample pump inlet pressure and power supply (bat tery) 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 la ck 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 c alibration 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 r esponse. However, we are not currently in possession of a C-21 to test this theo ry and attempts by EES to obtain a replacement have, to this date, been unsuccessful.

We hope the results presented in this memorandum ar e of assistance to the PERC ATCM amendment process. Please direct questions re garding the portable analyzer evaluation results to Angus MacPherson at 445-4686 or amacpher@arb.ca.gov

.H-5Table 2Portable VOC Analyzer Response to 25 ppmv and 50 ppmv PERC Calibration Gas StandardsDateAnalyzer(display, detection, delivery)PERCstandardconc.# TrialsAverageResponseas PERCResponseTime (sec)Notes(see text for discussion)28 Jan 05 50 ppmv 431 Jan 05tif – 5100(audible, semiconductor, diffusion)25 ppmv 3rapid beep < 5beep frequency can beinfluenced by flow past sensor28 Jan 05 50 ppmv 431 Jan 05Eco Sensors C-21(LED,semiconductor, diffusion)25 ppmv 3noresponsenaresponds to felt tip pen. mayrequire humidified sample.50 ppmv 3 49.5 ppmv < 523 May 05PhoCheck(LCD,PID,internal pump)25 ppmv 3 26.8 ppmv < 550 ppmv 3constant tone< 523 May 05Tek-Mate(audible, semiconductor, diffusion)25 ppmv 3constant tone< 5constant tone produced inboth high and low ranges.50 ppmv 323 May 05D-Tek(audible/LED,infrared, diffusion)25 ppmv 3noresponsenaprimary analyzer application isrefrigerant leak detection.50 ppmv 3 58.0 ppmv 5 – 1010 Aug 05Micro 5(LCD,PID,diffusion)25 ppmv 3 26.4 ppmv 5 – 10gas flow and pressure mayaffect analyzer response.50 ppmv 4 29.6 ppmv 11010 Aug 05Drager(LCD, chem. cellinternal pump)25 ppmv 3 20.7 ppmv 110excessive response time. poorresults for 50 ppmv standard.32 ppmv 2 30 ppmv 20 – 3023 Aug 05Aeroqual 200(LCD, semiconductor, diffusion)16 ppmv 2 15 ppmv 20 – 3025 Aug 05Aeroqual 500(LCD, semiconductor, diffusion)36 ppmv 1 31 ppmv 20 – 30analyzers require humidifiedsample for proper response.50 ppmv 3 50.7 < 506 Sep 05MiniRae2000(LCD, PIDinternal pump)25 ppmv 3 24.2 < 550 ppmv 8 48 ppmv < 5All DatesHW – 101(analog, PID,internal pump)25 ppmv 8 26 ppmv < 5reference analyzer.

### Appendix I

Contact Information for Alternative SolventsI-1Contact Information for Alternative SolventsSolvent Company Address City State ZipCode PhoneDF-2000ExxonMobil Chemical Co. 13501 Katy Freeway HoustonTX 77079 (281) 870-6000PureDry3M Global Headquarters 3M CorporateHeadquarters, 3M CenterSt. Paul MN 55144 (800) 364-3577EcoSolvChevron PhillipsChemical Company, LLC10001 6 Pine Drive Woodlands TX 77380 (832) 813-4100Shell Sol 140 HT Shell Chemical LP 7594 Highway 75Geismar LA 70734 (225) 201-6222GreenEarth(D5)Dow Corning Corporation 2200 W. Salzburg Road Midland MI 48686 (989) 496-4400RynexRynex Cleaning Solutions 7600 Jericho Turnpike Woodbury NY 11787 (516) 364-0800Stoddard Qualitek International 315 Fairbank StreetAddison IL 60101 (630) 628-8083ResolveR. R. Street & Co. Inc. 184 Shuman Blvd. NapervilleIL 60563 (800) 478-7338ImpressLyondell Chemical Co. 1221 Mckinney St., OneHouston Center, Suite 100Houston TX 77252 (713) 652-7200Hydroclene Caled Chemical 26 Hanes Drive Wayne NJ 07470 (800) 652-2533

### Appendix J

Electricity Cost CalculationsJ-1 Electricity Cost Calculation

Equation 1 was used in combination with the informa tion provided to us from the Machine Manufacturer Survey to calculate m aximum 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 determin e the kW that a typical load would draw. (JE, 2003)

(2) Typical Load kW = (Maximum Operating Load)(30 p ercent)

To calculate the hours that the machine runs Equati on 3 was used.

(3) Hours Ran = (cycles/day)(minutes/cycle)(60 minu tes/hour)

Where:

Hours Ran = the hours that the machine runs for o ne day Cycles/day = 6 cycles per day for a typical dry c leaner 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 p er 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 $0.1 0.
kW

Typically a facility will dry clean 5 days a week. Equation 5 was used to determine the annual electricity cost for a facilit y to run their machine.

(4) Cost Per Year = (cost per day)(5 days/week)(52 weeks/year)

### Appendix K

Summary of CommentsK-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 i s a statement, "GreenEarth Cleaning, who distributes th e 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 m anufacturers, 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 i t cannot contaminate the soil. Using these studies as reference, the Sil icones Environmental, Health and Safety Council (SEHSC) has concluded the follow ing about D5: "In the soil, degradation and volatilization occurs within a week . D5 ultimately degrades to inorganic silicate, or sand, water, and carbon diox ide."

3. Page VI-3, Section VI.C. : "The change in the amount of waste generated fro m solvent-based technologies (i.e., hydrocarbon, Gree nEarth and Rynex) is relatively small compared to perc."

Comments : The above statement is attributed to a report do ne by Jacobs Engineering, which did not include site visits or i nterviews with dry cleaners. Their conclusion in Section 5.2.8 of their report i s not attributed to any actual supporting documentation and appears to be merely a n assumption.

Dry cleaners using the GreenEarth process in variou s types of machine configurations, with and without stills, report a s ignificant decrease in the amount of waste generated versus perc or hydrocarbon. We have attached letters from current Affiliates documenting their actual experie nce.

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 acceptabl e for purposes of this report.

4. Page VII-1, Table VII- I and Page VII-3, Table V II-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 $36,0 00 to $98,000. Then, usingK-2

an average machine price range for each, Table VII- 2 shows that a machine using GreenEarth Cleaning costs $2,000 more than on e using hydrocarbon.

Comments : We understand that this information came from th e Machine Manufacturer Survey. However, in reality a dry cle aner cannot purchase a machine that uses only hydrocarbon that is less exp ensive 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 r eflect reality. To support this, we have attached a letter from Jim Carroll, Nationa l 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 make s the data collection much more subjective and less reflective of the act ual cleaning process itself. Such factors as experience of the finisher, relativ e 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 sol vents.

• The therm usage for GreenEarth reflected in this one study is not representative of reports from actual GreenEarth Af filiates.

6. Page VII-6, Table VII-5: The annual operating cost for GreenEarth Cleaning is reported as higher than actual operating costs repo rted 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 the rm usage is addressed in Item 4 above. Maintenance costs for G reenEarth are shown at $850 versus $250 for hydrocarbon. This is puzzling since the machines used
and the recommended maintenance schedules are virtu ally identical for both solvents. This information apparently came from th e 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 ap proved suppliers of D5, the GreenEarth Cleaning Solvent. Contact in formation for the other two is:K-3

• General Electric Advanced Materials, 187 Danbury R d., Wilton, CT 06897.

• Shin-Etsu Chemical, 115 0 Damar Dr., Akron, OH 44 035.

Silicones Environmental Health and Safety Council o f North America (SEHSC) November 23, 2005

1. In its report, the ARB has acknowledged the exte nsive health research submitted by the silicones industry in June 2005 to ARB, othe r 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 t he current state of the knowledge regarding the safety of D5. Because the additional research specifically addresses the uncertainties that are m entioned 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 pe rtaining to cyclic siloxanes. SEHSC urges ARB to either update the Draft Report t o reflect the current state of the knowledge regarding the safety of D5, or remove from Appendix G any information that pertains to D5 and, correspondingl y, 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 comment s.

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 Appen dix G as it has been superseded by subsequent research. This is particu larly important as the additional research addresses ARB’s and OEHHA’s con cerns. A majority of SEHSC’s specific comments address how the post-2003 research will change the conclusions of the December 2003 OEHHA evaluati on.

3. SEHSC would like to call to the attention of ARB that D5 is a nonsmog-forming material, which is a requirement for any alternativ e dry cleaning technology under California Assembly Bill 998. D5 has been classifi ed 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 Impact s—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 200 3).” Mode-of-action research submitted to U.S. EPA and California regul atory agencies by SEHSC in June 2005 indicates that the uterine findings are s pecific to the rat and do not represent a hazard to humans.

5. Section V.B.2. Page V-4. Potential Health Impact s—Volatile Methyl Siloxanes; The Draft Report states: “Because D5 is lipophilic there is also concern that D5 may bioaccumulate in the food chain.” The silicone s industry has conductedK-4

extensive adsorption, metabolism, and excretion stu dies with D5 (Reddy et al. In Progress, Smith 2005, Plotzke 2001, Plotzke In Prog ress). These studies clearly
show that D5 does not bioaccumulate in the food cha in 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 Impact s—Volatile Methyl Siloxanes; The Draft Report notes a liver weight increase in a subchronic study with D5. Additional research on this effect, including chron ic studies, show that this effect
of D5 in rat liver is an indication of a non-advers e metabolic adaptation, not a
toxic effect.

7. Table V-2. Page V-8. Summary of Interim Health V alues: The State of California has an established procedure for calculating a chro nic 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 phenobarbi tal-like activity, it has little or no relevance to humans (Whysner et al. 1996, Roberts e t 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 pr eferentially over the 90-day study. Therefore, to do a risk characterization or risk assessment and to assign a chronic REL for phenobarbital-like compounds base d solely on liver enlargement in rodents is not appropriate, especial ly from a 90-day subchronic study. Furthermore, there is reference in the OEHA A 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 th e spleen in this subchronic study.

We believe it would be inappropriate for OEHHA to s et any exposure limits until the D5 two-year, combined chronic/carcinogenicity s tudy and accompanying mode-of-action work provided in June 2005 are thoro ughly 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, wou ld allow for the setting of an exposure limit based on sound scientific data.

8. Section VI.A. Page VI-2. Groundwater Contaminati on: The Draft Report states “Based on preliminary findings from a study conduct ed by [SEHSC], the GreenEarth solvent is unlikely to leach into ground water because it is not soluble and readily sticks to soil particles (GreenEarth 20 03).” It should be noted that GreenEarth 2003 actually states “Based on conclusiv e 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 e vaporate 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 d egradation (within one week) in dry soil; ultimately degrading to inorganic silicat e (sand), water, and carbon dioxide (Xu and Chandra 1999). In the atmosphere, the majority of D5 willK-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—S oil: The Draft Report notes all dry cleaning processes can result in soil conta mination through accidental spills or releases. ARB should be aware that any D 5 accidentally released to the environment in a spill will readily evaporate or un dergo 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 incr ease 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 i nappropriate toxicological assessment of D5 and should be replaced with an upd ated review.

12. Appendix G - Health effects of D4 (Octamethylcy clotetrasiloxane) in animals:
SEHSC recommends that ARB remove the discussion of D4 from Appendix G, as D4 is not used as a dry cleaning solvent. Shoul d these irrelevant references to D4 be retained, they should be amended to reflec t the comments previously submitted by SEHSC (SEHSC 2004). These comments wi ll 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 b y the U.S. EPA and by all 50 states as well as by most of the air districts with in the State of California.

14. Appendix G - Health effects information on D5 i n the peer-reviewed literature: D5 does not have estrogenic or anti-estrogenic acti vity. Reference to the work of Hayden and Barlow (1972) is not appropriate. The c yclic phenyl-containing siloxanes assessed by Hayden and Barlow are not str ucturally analogous to D5. D5 does not have estrogenic or anti-estrogenic acti vity. There were no effects seen in the D5 two-generation reproductive study (W IL Research 1999). D5 was negative in the rat and mouse uterotrophic assay (Q uinn 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 recep tor activation using the MCF-7 cell line (Quinn 2005).

15. Appendix G - Health effects information on D5 i n the peer-reviewed literature:
Liver Effects in Rats. As for the liver effects seen with D5, it has been wellK-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 i n 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) revea ls that authors did
not conduct a mass balance determination of D5 and were unfamiliar with sample preparation and analytical techniques for si loxanes. As a result, the data reported by these authors in this paper are mislead ing.

17. Appendix G - Health effects information on D5 i n the peer-reviewed literature: D5 is non-genotoxic. Studies conducted with D5 include Salmonella typhim urium and Escherichia coli reverse mutation assays, an in vitro chromosome aberration test, and a combined in vivo rat micronucleus and U DS Assay (OECD 474, OECD 486). All of these studies on D5 were negativ e for genotoxicity activity (Sokolowski 2003, Schultz 2003, Honavar 2004).

18. Appendix G - Health effects information on D5 i n the peer-reviewed literature:
Uterine Tumors in Rats. As noted above, the increased incidence of uterine tumors was not accompanied by an increase in incide nce 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 p rolactin. This reduction in prolactin causes a reduction in the estrogen:proges terone ratio leading to estrogen dominance. This effect is considered rats pecific since this pathway does not occur in humans (SEHSC et al. 2005).

19. Appendix G - Interim inhalation chronic Referen ce 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 an y 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 h ave very different biological activities and different hazard profiles. Consider ation of the two materials together may lead to false conclusions.

20. Appendix G - Interim inhalation chronic Referen ce Exposure Level (REL): The State of California has an established procedure fo r 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 i ncrease 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. 198 9). In addition, a chronic study has been completed with D5, and this study sh ould be used preferentially over the 90-day study. Therefore, to do a risk cha racterization or risk assessment and to assign a chronic REL for phenobar bital-like compounds based solely on liver enlargement in rodents is not appropriate, especially from aK-7

90-day subchronic study. Furthermore, there is ref erence 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 n o effects seen on the spleen in this subchronic study.

We believe it would be inappropriate for OEHHA to s et any exposure limits until the D5 two-year, combined chronic/carcinogenicity s tudy and accompanying mode-of-action work provided in June 2005 are thoro ughly 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, wou ld 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 Impress TM solvent for dry cleaning. Impress solvent is a proprietary composi tion containing prdominantly dipropylene glycol n-propyl ether (DPnP). Lyondell is providing additional information on mammalian toxicity and ecological st udies 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 parag raph with the following: Chevron Phillips Chemical Company LP manufactures EcoSolv® Fluid (EcoSolv). This dry cleaning fluid is predominantly a mixture of sy nthetic isoparaffins with carbon numbers ranging from C9 to C13. The manufacturer f ormulated this product by adding butylated hydroxytoluene at 10 parts per mil lion (ppm) to act as an oxygen stabilizer. This solvent is a high purity a liphatic 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 process ing, 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 o F, and is classified as Class IIIA solvent per NFPA 32. (ARB, 2004h)

2. IV-A-3, Page IV-5: The text states that the gro up was not aware of any cleaners using EcoSolv® fluid in California. Chevron Philli ps 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 fa te of our product has been evaluated and data submitted to the OECD SIDS HPV I nitiative with US EPA as Sponsor. Biodegradation data available show that C 10-C13 isoparaffinic hydrocarbons can exhibit a moderate to rapid rate o f biodegradation. In a ReadyK-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 a nd EcoSolv® DCF from Chevron Phillips. We recommend modifying the gener ic references to DF-2000 to synthetic/Isoparaffinic solvents which include b oth DF-2000 and EcoSolv®
DCF.

6. The page numbers in section I might have been nu mbered 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 bo th flammable and combustible. Rynex should not be listed as hazardous because it’ s combustible since they are all combustible. Please change this and also remov e the carcinogenic reference since Rynex is non-carcinogenic. Petroleum’s and s ilicones cannot make this
claim.

ExxonMobil Chemical Company, November 29, 2005

1. Page II-2: Include Flash point for DF-2000 Flui d of 144 o F.

2. Page IV-7: The REL for DF-2000 Fluid is 171 ppm or 1200 mg/m 3 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 uni ts on the REL correct?

4. Pure-Dry-4 references the Phillips and Egan stud y (1984). Please note that the effects were related to male rat kidney effects tha t U.S. EPA has determined to be species/sex specific. Is it appropriate to use this study?

5. Page V-3, 5 th paragraph: DF-2000 Fluid contains C11-C13 synthet ic isoparaffin aliphatic hydrocarbons.

6. Page V-4, 1 st sentence: Check the last word in the first senten ce of the page;
should be rats and not rates?

Aeroqual Limited, November 18, 2005

1. Aeroqual has provided for testing their new perc hloroethylene leak detector sensor head with Aeroqual Series 200 handheld monit or. 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 Ta ble 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. Comparis on of Cost for Perc
Concentration Detectors because the cost of the Aer oqual Series 200 Leak
Detector is the same as the standard Series 200 han dheld 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 shou ld be changed from $2,745 to $1,999.

Turlock Dry Cleaning, November 19, 2005

1. I am the owner of Turlock Dry Cleaning in Turloc k, CA. I personally like the strength and effectiveness of Perc and am willing t o 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, 2 nd to last paragraph – In addition to noting that PER C 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 incre ased 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 t he other hydrocarbons discussed in this section, and already are availabl e to the industry.

3. Page II-3, D. Rynex Cleaning – This section shou ld be retitled “Propylene Glycol Ether Solvent Cleaning” and the discussion of Impre ss Solvent (page II-6) should be included. Both Impress and Rynex are P-series g lycol ethers and have similar properties. Impress also is already availa ble to the industry.K-10

4. Page V-1, 1 st paragraph – The fourth sentence of the paragraph s hould be rephrased to read “Many of the human studies have b een 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) C leaning. Suggest changing the language in the first paragraph, 4 th statement, to “It is considered to be nonhazardous under OSHA Hazardous Communication Standa rds because it is a non-combustible liquid. It is also considered a no n-regulated VOC because of its low volatility rating.”

2. Page V-4(3) RynexTM (Propylene Glycol Ether): Pl ease 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 ha ve. 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 Dr inking Water Act or as a hazardous air pollutant (HAP). It is noncarcinogen ic, biodegradable and has low toxicity. It is also not classified as hazardous w aste material.

Most reporting and special paperwork is eliminated because RynexTM has not been designated as a hazardous chemical by the Fede ral EPA. RynexTM can be used in any hydrocarbon machine with minor modifica tions. Most manufacturers now offer RynexTM ready machines in capacities to me et 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 remove s 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: (stat ement 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 classif ied as a 3B liquid and is not a potential fire safety hazard.K-11

2. Page VII-6: Chart: Under RynexTM it now reads: A verage cost for detergents/spotting agents $1500.00 per year. It s hould 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 Res ources Board (ARB) staff was not able to locate any independent efficacy testing for RynexTM. However, the manufacturer claims that RynexTM is a superior, gent ler 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 (Ry enx, 2005), although this has not been verified with independent testing.

It should read: The manufacturer claims that Rynex TM is a superior, gentler cleaner (when compared to Perc) that can handle a w ide variety of fabrics. They
also claim that it removes water soluble stains bet ter than other solvents, this has been verified with those cleaners using RynexTM as a true statement (Please delete the beginning and ending statements regardin g the independent testing and unverified documentation).

### Appendix L

Glossary and AcronymsL-1



### Glossary

Acute Exposure: One or a series of short-term expos ures generally lasting less
than 24 hours.

Agency Shop: Same as drop off shop. Facility with n o dry cleaning machine
on-site.

Airborne Toxic Section 39655 of the Health and Safe ty Code, defines an
Control Measure: “Airborne Toxic Control Measure” m eans either of the following:

1) Recommended methods, and, where appropriate, a range of methods, that reduce, avoid, or eliminate the em issions of a
toxic air contaminant. Airborne toxic control meas ures include, but are not limited to, emission limitatio ns, control technologies, the use of operational and maintenanc e conditions, closed system engineering, design equip ment, or work practice standards, and the reduction, avoidan ce, or elimination of emissions through process changes, s ubstitution of materials, or other modifications. 2) Emission standards adopted by the U.S. Environm ental Protection Agency pursuant to section 112 of the fe deral act (42 U.S.C. Sec. 7412).

Air Dispersion A mathematical model or computer si mulation used to Model: estimate the concentration of toxic air poll utants at specific locations as a result of mixing in the atmosphere.

Chronic Exposure: Long-term exposure usually lastin g 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 liqu id 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 materia l.

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 mo re than one type of dry cleaning process.L-2

Permissible Exposure The maximum amount or conc entration of a chemical that a Limit (PEL): worker may be exposed to under the Occ upational Safety and Health Administration (OSHA) regulations.

Risk: The possibility of injury or diseas e, 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 Pes ticide Regulation in their Contaminants (SRP): evaluation of the adverse healt h effects toxicity of substances being evaluated as Toxic Air Contaminants.

TIF Detector Halogen leak detector made by TIF TM Instruments, Inc.

Toxic Air Section 39655 of the Health and Safety C ode, defines a TAC Contaminant (TAC): as an air pollutant which may ca use or contribute to an increase in mortality or an increase in serious ill ness, or which may pose a present or potential hazard to human hea lth. A substance that is listed as a hazardous air polluta nt pursuant to subsection (b) of section 112 of the federal act (42 U.S.C. Sec. 7412(b)) is a TAC. TACs that are p esticides are regulated in their pesticidal use by the Depart ment of Pesticide Regulation.

Volatile Organic Means any compound containing at l east one atom of carbon, Compound (VOC) excluding carbon monoxide, carbon di oxide, carbonic acid, metallic carbides or carbonates, and ammonium carbo nate, 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-tetrafluoroethan e (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 fluorina ted alkanes; 2. cyclic, branched, or linear, completely fluorina ted ethers with no unsaturations; 3. cyclic, branched, or linear completely fluorinat ed tertiary amines with no unsaturations; and 4. sulfur-containing perfluorocarbons with no
unsaturations and with the sulfur bonds to carbon a nd fluorine, and

(B) the following low-reactive organic compounds wh ich have been exempted by the U.S. EPA: acetone, ethane, me thyl acetate, parachlorobenzotrifluoride (1-chloro-4-tri fluoromethyl 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 A ssociation CAS Chemical Abstract Service CG Cellulose gum CEQA California Environmental Quality Act
CO 2 Carbon Dioxide CTSI U.S. EPA’s Cleaner Technologies Substitute Ass essment :

Professional Fabricare Processes

D 5 Decamethylcyclopentasiloxane DfE Design for the Environment DHS California Department of Health Services Districts Local Air Pollution Control and Air Quali ty Management Districts DOF California Department of Finance DPNB Dipropylene Glycol Normal Butyl Ether DTSC California Department of Toxics Substances C ontrol

° 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 Assista nce

KB Kauri Butanol Kg Kilogram
kWh Kilowatt-hour

Lauramide DEA lauric acid diethanolamide LOC Local ventilation systemL-5

m 3 Cubic meter
MDL Minimum Detection Limit μg/m 3 Microgram per cubic meter MSDS Material Safety Data Sheets

NESHAP National Emissions Standards for Hazardous A ir Pollutants NIOSH National Institute for Occupational Safety a nd Health NTP National Toxicology Program

OEHHA Office of Environmental Health Hazard Assess ment OSHA Occupational Safety and Health Administratio n

P-20 Ethoxylated sorbitan monodecanoate PBR Partial vapor barrier room PEL Permissible Exposure Limit Perc Perchloroethylene pH A logarithmic measure of hydrogen ion concentr ation
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 Coun cil of North America SLI Sodium lauryl isethionate
SLS Sodium laureth sulfate
SRP Scientific Review Panel on Toxic Air Contamina nts

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 Ag ency

VBR Vapor Barrier Room VOC Volatile Organic Compound