north carolina department of environment and natural ...figure 4 cyclic siloxane dry-to-dry process...

North Carolina Department of Environment and Natural Resources Division of Pollution Prevention and Environmental Assistance

Michael F. Easley, Governor William G. Ross Jr., Secretary Gary Hunt, Director

1639 Mail Service Center, Raleigh, North Carolina 27699-1639 Phone: (919) 715-6500 \ FAX: (919) 715-6794 \ Internet: www.p2pays.org An Equal Opportunity \ Affirmative Action Employer – 100% Recycled \ 100% Post Consumer Paper

December 13, 2001 Mr. Gary Hunt, Sponsor Dry Cleaning Alternatives Study Group Dear Gary: Attached is the final report of the study group on Alternatives to the Predominant Dry Cleaning Processes. Some of the findings are substantially different from what many of us understood about this industry at the beginning of the study. New findings determined during the study include: 1. The use of the current predominant solvents has been reduced significantly over the past few years,

but considerable opportunities exist for improving the efficiency of the PERC and petroleum processes, and perhaps the efficiency of new processes. This study group recommends that additional improvements by encouraged rather than required by statute. This recommendation is based on sensitivity to the capital costs involved and the primary structure of the North Carolina dry cleaning industry being small, family owned businesses.

2. The North Carolina Occupational and Environmental Epidemiology Branch and several other credible

sources/reviewers believe there is no credible evidence to associate PERC as used in the dry cleaning industry with cancer.

3. The solvent/detergent systems used in the new processes, Petroleum Class IIIA, cyclic siloxanes, and

carbon dioxide are not hazardous materials according to EPA but are hazardous materials according to OSHA. This raises the question of whether they are eligible for the 20% tax credit for purchases of new technologies as offered by HB 1583.

The study group tried to look at all aspects of each process in considerable detail, and to fully evaluate each of them in a critical manner. Hopefully, this approach will aid Secretary Bill Ross of DENR and the North Carolina General Assembly in the future analysis of the advisability and feasibility of accepting and/or encouraging any of the current or alternative processes for the tax credit. Most of the parties involved in the development of this report would prefer that various parts of this report were written to show more favorably the areas they represent. However, we did agree that we should not promote one particular process over another, as the market will determine the merits of each. Most of the members openly and freely contributed their experience and expertise to this study and conducted themselves in a constructive manner. Many aspects of the industry were debated in depth, and the group usually reached a consensus. On behalf of the study group, Bill Albright

ALTERNATIVES TO THE PREDOMINANT DRY CLEANING PROCESSES

North Carolina Department of Environment and Natural Resources

Study Group Report

To Fulfill Request by the

North Carolina Legislature

HB 1326 SL 2000-19

October 2001

N.C. Dry Cleaning Alternatives Study October 2001

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Alternatives to the Predominant Dry Cleaning Processes

Table of Contents

Study Group Membership iii Key Definitions iv Executive Summary Findings 1 Recommendations 6 Legislation Proposals 7 Organization and Implementation of Study Task of Study Group 9 Assignment and Approach of the Study Group 10 Current Predominant Processes and Alternatives 10 Master Matrix 11 A Brief Overview of the North Carolina Dry Cleaning Industry 11

A Brief History of the U.S. and North Carolina Dry Cleaning Industries 12 Labeling 13 The Cleaning Process – Roles of Chemicals, Quality, Problems 13 Diagrams of the Dry Cleaning Processes 16

Trends in Dry Cleaning Industry Solvent Usages, Equipment Improvements, Environmental Impacts, Safety PERC 22 Class II Petroleum Cleaning 29 Class IIIA Petroleum Cleaning 29 Cyclic Siloxanes 34 Liquid Carbon Dioxide 36

Wet Cleaning 38

Each process section concludes with Findings, Recommendations, Legislation Proposals


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Public Health Hazard Impacts Professional Studies and Evaluations PERC 46 Petroleum Solvents – Class II 51 Class IIIA Solvents 52 Miscellaneous Reports on Dry Cleaning Solvents 52 Findings, Recommendations 53 Conversion Alternatives and Key Factors Financial Health of the North Carolina Dry Cleaning Industry 54 Capital Requirements for Converting 55 Converting from PERC to Five Alternatives 55 Converting from Class II Petroleum to Five Alternatives 58 Dry Cleaning Legislation Proposed Changes – HB 1583 64 - PERC Regulations 66 - Petroleum Regulations 67 Appendix Master Matrix – Table of Key Factors for the Dry Cleaning Industry 71 Report of N.C. Occupational and Environmental Epidemiologists 73 Brief Bios of Study Group 87 Study Group Attendance Record 89 Tables and Figures Table 1 North Carolina 1997 Dry Cleaners Survey 42 Table 2 PERC Dry Cleaning Equipment Generations 43

Table 3 North Carolina 1997 Petroleum Solvent Usages 44 Table 4 Solvent Classifications and Petroleum Equipment 45 Table 5 Converting From PERC 62 Table 6 Converting From Petroleum 63 Table 7 Dry Cleaning Legislation 68 Table 8 Master Matrix 71 Figure 1 PERC Dry-to-Dry Process Flow Diagram 16 Figure 2 Petroleum Transfer Process Flow Diagram 17 Figure 3 Petroleum Dry-to-Dry Process Flow Diagram 18 Figure 4 Cyclic Siloxane Dry-to-Dry Process Flow Diagram 19 Figure 5 Liquid Carbon Dioxide Process Flow Diagram 20 Figure 6 Wet Cleaning Process Flow Diagram 21 Figure 7 PERC Demand in U.S. Dry Cleaning Industry 41


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Dry Cleaning Alternatives Study Group Membership Nonprofit Conservation Organizations David Knight, Sierra Club of North Carolina Lou Zeller, Blue Ridge Environmental Defense League Dry Cleaners

Chris Edwards, A Cleaner World – PERC, Petroleum, Wet Cleaning Sto Fox, Executive Director, N.C. Association of Launderers and Cleaners Lindley Smith, Sno White – Petroleum Dry Cleaner Martin Young, Young Cleaners – Petroleum Dry Cleaner Mary Wells, Koretizing – PERC and Wet Cleaner John Parks, Fashion Care – PERC and Korean Representative Mack Davis, Medlin-Davis – PERC and GreenEarth Equipment Manufacturers/Distributors Joe Herndon, Consolidated Laundry Equipment Guy Bunn, Bunnco Inc. Dr. James McClain, Micell James Barry, GreenEarth

Solvent Manufacturers and Representatives Steve Risotto, Halogenated Solvent Industry Alliance Messrs. Smith and Young – represent petroleum solvents Dr. James McClain – represents the CO2 industry James Barry – represents the cyclic siloxane industry Research Dr. Manfred Wentz, N.C. State University, College of Textiles Mary Scalco, International Fabricare Institute DENR Staff Tony Pendola, DENR, Small Business Assistance Office

Group Sponsor Gary Hunt, Director, Division of Pollution Prevention and

Environmental Assistance (DPPEA) Team Leader: Bill Albright, DPPEA Facilitator: Norma Murphy, DPPEA


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Key Definitions For anyone unfamiliar with the terminology used in the dry cleaning industry, following are a few key definitions: Dry clean process the cleaning of fabrics with organic solvents such as

petroleum solvents, PERC. The process includes adding detergents and moisture to the solvent, up to 75 percent relative humidity, and hot tumble drying to 160 °F.

Professional wet cleaning a process for cleaning sensitive textiles (i.e., wool, silk,

rayon, linen) and removing certain stains and soils by skilled professionals using water, special technology, detergents and additives to minimize the potential for adverse effects. Appropriate drying and restorative finishing procedures follow this process. Until recent years, this term involved primarily very skilled hand- processing. New automated machine technology can make this process much more usable and efficient.

Transfer process a dry cleaning process in which the garments are cleaned

by immersion in a solvent in one machine and physically transferred to another piece of equipment for drying. During the transfer, the opportunity exists for release of solvents to the work environment.

Dry-to-dry process a dry cleaning process in which the garments are put into a

single machine that cleans and dries the clothes without opening the machine.

Commercial laundering a process by which textile products or specimens may be

washed, rinsed, bleached, dried and pressed in commercial laundering equipment, typically at higher temperatures, higher pHs and longer processing times than used for home laundering.

Solvent classifications Dry cleaning solvents are classified by the National Fire Protection Association (NFPA) according to their flash

points. The petroleum Stoddard solvents are Class II with flash points below 140 °F, and the new petroleum solvents are Class IIIA with flash points above 140 °F. The new cyclic siloxanes are Class IIIA solvents, as is the detergent mixture used in at least one of the carbon dioxide process. PERC is a Class IV because it is considered nonflammable.


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PERC an abbreviation for the dry cleaning solvent

perchloroethylene, sometimes called tetrachloroethylene Petroleum solvents a class of solvents derived from petroleum which include

such solvents as the Stoddard class, Exxon DF 2000, Shell 140, etc.

Stoddard solvents a class of specially formulated petroleum fractions for the

dry cleaning industry to replace white gasoline, originally introduced in 1932. This class has been expanded over the years, and includes names such as varsols, quick dry, naphthas, mineral spirits, etc.

Hydrocarbons chemical compounds made up only of carbon and

hydrogen. Cyclic siloxanes a chemical compound made up of silicon, oxygen, and

small hydrocarbon groups. Trade names include GreenEarth and PureGreen.

Carbon dioxide a chemical compound, a gas at room temperatures and

pressures, and can be converted into a liquid at about 800 pounds per square inch (psi.) The EPA has determined it is a significant cause of global warming and has initiated programs to reduce its production by electric power plants. The use of carbon dioxide in the dry cleaning industry is not a contributor to the production of carbon dioxide, and therefore should not be affected by EPA classifications. Company names include Micell, Chart, Alliance and SailStar. Trade names include MiCare/Hangers® and DryWash.

Glycol ethers a potential new dry cleaning solvent composed primarily of

propylene glycol ether, which is derived primarily from petroleum. Trade names include Rynex.

Machine generations Table 2 shows the PERC machine improvements and the

labels given them by the industry. The petroleum machines are covered in Table 4.

$K = $1,000 $M = $1,000,000


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Executive Summary The Study Group on Alternatives to the Predominant Dry Cleaning Processes was initiated by the North Carolina General Assembly in Section 21 of House Bill 1326 of Session Law 2000-19. The N.C. Department of Environment and Natural Resources (DENR) was instructed to assemble a balanced group of stakeholders to identify and evaluate alternative dry cleaning processes, identify historical trends, evaluate benefits and costs of alternative processes, and evaluate the feasibilities of implementing these new processes and equipment. The study group was asked to present its findings, recommendations and legislation proposals. The most widely used dry cleaning solvent in North Carolina is perchloroethylene (PERC), and it is listed as a hazardous substance by the federal Environmental Protection Agency (EPA.) The primary concerns about PERC have been its potential toxicity to people working in the industry, to the people living above or adjacent to dry cleaning operations, to the general public that wear the dry cleaned clothes, and to groundwater contaminated with PERC. The EPA classifies PERC as being between a B and a C; that is, it is a possible carcinogen, but it is not a probable carcinogen. Past waste disposal practices have caused PERC to sink into the soil and groundwater under dry cleaning facilities, and numerous regulations have been enacted to control the handling and disposal of PERC. There are more than 100 known sites in North Carolina contaminated with PERC to varying degrees. The second most widely used dry cleaning process in North Carolina uses petroleum- based solvents. The primary concern with these solvents has been their safety aspects due to their potential fire hazards. Although the petroleum solvents used for the past several decades have contained small amounts of chemicals known to be carcinogenic, these dry cleaning solvents have not been classified as being possible carcinogens, and thus have not raised the same concerns as for PERC. The North Carolina General Assembly has enacted legislation which provides state tax credits for those who purchase and install certain types of dry cleaning equipment and processes, and has imposed privilege and excise taxes on the purchase of PERC and petroleum dry cleaning solvents, although the taxes on petroleum solvents are lower than for PERC. The EPA has partially funded the development of new dry cleaning processes. Following are the major Findings, Recommendations and Legislation Proposals of this study group. Additional items can be found at the end of each report section. Findings Current and Alternative Processes

1) The two current predominant dry cleaning processes in North Carolina are PERC and Petroleum Class II. Both processes include up to10 percent wet cleaning as a supplement in order to clean all types of fabrics and soils. (see page 10 for more detail)


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2) There are five alternatives for further reducing solvent usages and/or new

processes:

a. further reductions in the usages of the PERC and Class II petroleum solvents in the current processes

b. increased use of wet cleaning with all processes c. liquid carbon dioxide (CO2) plus wet cleaning plus solvent d. cyclic siloxanes plus wet cleaning e. the new Class IIIA petroleum solvents plus wet cleaning

Solvent Usages

3) Usages of PERC in the dry cleaning industry have dropped rather dramatically (by 75-80 percent) during the past 15 years, as shown in Fig. 7, and there are several possibilities for further significant efficiency improvements and reductions. Essentially all of the transfer-type machines have been taken out of service due to the higher costs of PERC, due in large part to the solvent use tax implemented in 1997. The average efficiency of the North Carolina PERC dry cleaners in 1997 was 272 lbs. of clothes cleaned per gallon of PERC used. Industry studies by the International Fabricare Institute (IFI) indicate the efficiency could be raised to at least 600 lbs/gal if the equipment were upgraded to the new Generation 4 level. (see pages 22-24 for more detail)

4) The primary petroleum solvents have been the Class II Stoddard solvents,

which are classified as hazardous because their flash points are below 140°F. The study group did not obtain industry-wide usage numbers, but usages of these solvents in the petroleum transfer process have been reduced by about 90 percent with installation of the new solvent recovery dryers and vacuum stills, with a good return on the investment. A relatively new Class IIIA petroleum solvent exists that is not classified as a hazardous material by EPA, but is a hazardous material by OSHA standards. It cleans very well, although it requires somewhat longer cycle times. (See pages 29-32 for more detail)

5) The current reduced solvent usages could be further reduced substantially by

the following pollution prevention measures:

a. Upgrading PERC processes from Generation 3 machines to Generation 4.

b. Installation of solvent recovery dryers and vacuum stills in all petroleum transfer processes.

c. Additional operator training on the most efficient operating procedures of the equipment.

d. Increasing the use of wet cleaning significantly, from the current 10 percent level to as high as 70 percent, which would obviously further reduce the usages of the solvents. Wet cleaning as practiced in the past


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required great skill and was very labor intensive. The new high-tech machines make this process much more available to all dry cleaners. They require capital expenditures and higher labor costs, but lower solvent costs. While considerably more clothes could be wet cleaned, wet cleaning is not a potential complete replacement for any of the current or alternative processes. (see pages 23-24 for more detail)

Health/Environmental

6) PERC is not classified as a known human carcinogen by several studies and

peer level reviews of studies, although it has been shown to cause certain types of cancers in some rats. The EPA position is that PERC is a possible carcinogen, but not a probable carcinogen. The agency has come to this conclusion at least twice. The strongest statements by researchers claiming some association between PERC and cancer have been along the lines that PERC may reasonably be anticipated to be a carcinogen, but each of these study’s data obviously did not support claiming a clear link. Reviews by other organizations of these same studies along with other available data, including reviews by Health Canada and the UK Department of Health, have all come to essentially the same basic conclusion: that there is no credible evidence to associate PERC as used in the dry cleaning industry with cancer. The N.C. Occupational and Environmental Epidemiology Branch (OEEB) also reviewed the toxicities of PERC, particularly the potential hazards of PERC in groundwater. This agency agreed with the above-mentioned studies and concluded that the current regulations are appropriate. (see pages 46-51 for more detail)

7) The Petroleum Class II Stoddard solvents have not been classified as toxic or

even as possible toxics. However, they contain small amounts of some chemicals that are known to be carcinogenic. (see pages 51-52 for more detail)

8) The majority of groundwater contamination with PERC appears to have

occurred prior to the development of environmental regulations. The North Carolina rules and regulations for disposing of dry cleaning wastes have already been tightened well beyond the federal regulations. These improvements were made through joint efforts of the North Carolina General Assembly, DENR, environmental groups and the dry cleaning industry. The World Health Organization’s drinking water limit of 40 parts per billion (ppb) of PERC is about eight times higher than North Carolina’s limit of 5 ppb; Health Canada’s limit is about six times higher at 30 ppb. (see pages 25 and 49 for more detail)

9) Safety concerns of these processes have centered primarily on the potential fire hazards of the petroleum processes; PERC is not flammable. As


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mentioned above, the petroleum cleaners used primarily the Class II Stoddard type solvents with low flash points, and there were fires many years ago.

The fire regulations have been upgraded and tightened in the new NFPA 32 code, the petroleum equipment has been upgraded with instrumentation to try to prevent the existence of explosive mixtures, and the fire marshals are stricter about the installation and operation of these processes. This study group is not aware of any fires in the N.C. petroleum dry cleaning industry for at least the past 10 years.

The new Class IIIA petroleum solvents have flash points above 140 °F, and consequently are not classified as hazardous materials by the EPA, but they are hazardous materials by OSHA standards because their flash points are above 100 °F but below 200 °F. They are better environmentally because they contain very small amounts, if any, of the aromatic chemicals.

Cyclic siloxanes are Class IIIA solvents because they burn and have a flash point of 170 °F, and have the same hazardous material classification situation as the new petroleum solvents.

The hydrocarbon detergent mixture used in at least one of the CO2 processes is also a Class IIIA solvent with a flash point of 177 °F, and has the same hazardous material classification situation as the new petroleum solvents.

All of these new Class IIIA solvents are more acceptable environmentally with their higher flash points, but all of these materials are still significant fire hazards. (see pages 29-32 for more detail)

Potential Alternative Processes

10) The cyclic siloxane process plus wet cleaning appears to be a feasible, innovative and complete alternative. This process uses a Class IIIA solvent in essentially the same type of equipment used in dry-to-dry petroleum cleaning. It seems to clean all types of garments acceptably, and the manufacturers continue to work on improving the current solvent/detergent mixtures. The costs of converting to this process with GreenEarth from either PERC or Class II petroleum transfer facilities are in the $45,000 - $120,000 range, depending on the specific site of the store and volume processed. If the conversion were done using an existing petroleum dry-to-dry operation, the cost could be as low as $1,500. The current investments in PERC and petroleum machines would essentially be lost if required to purchase new equipment, as the GreenEarth process requires. This alternative appears to be a relatively low business risk in that if it turns out to be unacceptable in the market place, the equipment could be converted rather easily to a petroleum Class IIIA operation.


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As of this study, GreenEarth reports having sold over 130 processes in the United States since its introduction in 1999. It is too early to draw any conclusions about acceptance by the general public. (see pages 34-35 for more detail)

11) The carbon dioxide (CO2) process plus wet cleaning appears to be a feasible,

innovative alternative, but apparently is not a complete alternative at this time, as some of the current operations have found it necessary to add solvent machines or outsource some clothes in order to handle all fabrics. They continue to work on improving the solvent/detergent mixtures. This process uses a Class IIIA hydrocarbon detergent mixture along with the carbon dioxide base solvent. The equipment is quite different from what has been used in the industry, and it operates in the 750-800 psi high-pressure range, which is of course, a potential safety hazard. The capital costs are higher and appear to be in the range of $100,000 - $180,000 if purchasing only a single machine. A Hangers® franchise involves much more than a machine, and it appears to cost in the $200,000 – $1 million + range, depending on the location and extent of an exclusive territory. The current investments in PERC and petroleum machines would essentially be lost.

This process has been in the field for about three years, and it is reported that 30 – 35 machines have been installed in the United States. It appears to be a higher business risk due to the higher investment costs and being a completely different type of process. If it turns out to be unacceptable in the marketplace, most of the investment would be lost. The combination of these factors may make this a less feasible alternative for the small businessperson. (see pages 36-37 for more detail)

Legislation

12) Petroleum dry cleaners with certain equipment that can hold over 84 lbs. are covered by Sect JJJ of the New Source Performance Standards (NSPS). North Carolina has a regulation that requires dry cleaners covered by JJJ to obtain a

North Carolina air permit. NC DENR DAQ has initiated actions with the N.C. EMC to rescind this permit requirement.

13) Every PERC processing location in the United States is scheduled to become

a Title V facility by Dec. 9, 2004, and could be required to pay the air permit fee of over $6,074/yr. (see pages 64-69 for more detail)

Financial Aspects

14) As shown in the Master Matrix, each dry cleaning store involves the

equivalent of capital investments in the range of $550,000 to $1 million, assuming all assets were purchased and none were leased or rented. After-tax cash flows (profits plus depreciation) range from $21,000 to $196,000 per


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year, with ROIs ranging from 4 percent to 20 percent. This study group estimates that 60-80 percent of the North Carolina dry cleaners are family-owned, single-store, small businesses. (see pages 54 and 71 for more detail)

Recommendations Health/Environmental

1) In view of the large reductions in both PERC and Class II petroleum solvent usages, and with both of these solvents not being classified as known human carcinogens, the question arises as to whether additional pressures and/or incentives should be applied to further reduce and/or eliminate the usage of either one or both of these solvents. Aside from its occasional medicinal uses, the study group feels the usages and emissions of PERC should be reduced as much as is prudent.

2) Accept the basic conclusion of the North Carolina Occupational and

Environmental Epidemiology Branch and other reputable organizations: PERC, as currently used in the dry cleaning industry, does not pose a significant human health risk to the general population.

Solvent Usages

3) Continue to encourage minimizing PERC and petroleum emissions to prudent levels.

4) Encourage additional training of operators to further reduce the usages of

these solvents.

5) Encourage the increased usage of professional wet cleaning.

6) Encourage the upgrading of PERC equipment from Generation 3 to Generation 4.

7) Encourage all petroleum transfer operations to install the new solvent

recovery dryers.

8) Ensure that NCDENR inspectors are properly trained to be knowledgeable of the functions, instrumentation and operations of all types of dry cleaning machines.


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Legislation

9) Ban new Class II petroleum transfer operations.

10) If all PERC dry cleaners become Title V facilities, encourage NC DENR Division of Air Quality (DAQ) and the Environmental Management Commission (EMC) to develop permit classifications, if possible, to reduce the Title V annual permit fee, currently $6,074 plus a small emissions-based fee. Such an annual permit fee would be a substantial percentage of a small dry cleaner’s annual profit. If possible, include incentives to reduce the usages of PERC.

11) Do not relax the North Carolina regulations for the disposal of

separator/contact water, though they are more restrictive than the federal regulations.

12) Continue the privilege/sales/excise tax on PERC and petroleum solvents, and

use it to fund the Dry Cleaning Solvent Cleanup Program.

13) Fund the following studies which could further reduce the usages of solvents: a. Evaluate the practical limits of the new wet cleaning processes b. Evaluate the in-situ drying of carbon filters

Financial Aspects

14) If the North Carolina General Assembly determines to continue encouraging the reduction in solvent usages, develop financial assistance programs to assist dry cleaners with capital outlays for further reducing the usages of solvents and for converting to alternative processes.

Legislation Proposals

1) To encourage the further reduction of the uses and emissions of PERC and Class II petroleum solvents, establish a financial aid program to assist dry cleaners with the acquisition and installation of equipment to further reduce the usages of the current solvents and the conversions to the new alternative processes.

Since the majority of North Carolina dry cleaners are small businesses, the preferred hierarchy of financial assistance is:

1. grants 2. low interest guaranteed loans 3. tax credits


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The amount of tax credits should be based on the levels of operator training, and additional wet cleaning where appropriate.

2) If the North Carolina General Assembly determines to continue providing tax

credits for purchasing and installing equipment and processes to reduce the usages of PERC and Class II petroleum solvents, revise some of the definitions in HB 1583, SL 1999-2000, and include the capital expenditures for other alternatives that would significantly reduce the usages of the current solvents, as listed in the items A – G on page 63.


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Organization and Implementation The Tasking of the Study Group House Bill 1326 of Session Law 2000-19 tasked the Secretary of North Carolina’s Department of Environment and Natural Resources (DENR) with studying the dry cleaning processes and equipment that are potential alternatives to the predominant dry cleaning processes and equipment currently utilized. DENR is to be assisted by a balanced working group of stakeholders including:

• Representatives of nonprofit conservation organizations • Representatives of the dry cleaning industry • Manufacturers of dry cleaning processes and equipment • Manufacturers of dry cleaning solvents • Researchers knowledgeable about garment cleaning and dry cleaning

The objectives of the study are to:

1. Identify alternative dry cleaning processes and equipment a. Currently in use b. Viable, potential alternatives

2. Identify the historical trends in the use of these processes and equipment 3. Evaluate the benefits and costs of the processes and equipment

4. Evaluate the feasibility of converting to new processes and equipment In evaluating the alternative processes and equipment, the following factors shall be considered at a minimum:

• The environmental and public health impacts of the processes and equipment • The ability of the processes and equipment to clean a wide variety of natural

and synthetic fabrics without damage • The ability of small business organizations to finance, own and operate the

processes and equipment • The effect of widespread use of the processes and equipment on fire safety

Further, if the Secretary of DENR finds significant potential obstacles to the implementation of beneficial alternative dry cleaning processes and equipment, the Secretary shall recommend to the General Assembly specific regulatory and non-regulatory policy measures to promote the increased use of such alternative processes. The Secretary’s report shall include

A) Findings B) Recommendations C) Legislative proposals


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Assignment and Approach of the Study Group The Secretary of DENR designated the Division of Pollution Prevention and Environmental Assistance (DPPEA) to be the lead agency for this study. This report is presented in the following sequence of sections: Executive Summary Introduction Trends – Solvent Usages, Equipment, Environmental Impacts, Safety Public Health Hazard Impacts Conversion Alternatives and Key Factors Convert from PERC to five alternatives Convert from Class II Petroleum to five alternatives Dry Cleaning Legislation and Proposals Master Matrix Appendix This study group proved to be knowledgeable, constructive and efficient, and contributed its broad expertise generously and openly. Most members readily supplied information, discussed the key factors in considerable detail, and rather easily came to consensus, or very near consensus, on the various items covered. Because the two most promising new processes have been field tested here in North Carolina, several members of the study group have very good knowledge and insight into their strengths and weaknesses. Current Predominant Processes and Alternatives The study group met several times, and agreed that the current predominant processes were PERC plus wet cleaning and Class II petroleum plus wet cleaning. They also agreed that only three alternative processes should be considered at this point: liquid carbon dioxide (CO2) plus wet cleaning marketed by Micell, Chart, SailStar and Alliance; cyclic siloxanes plus wet cleaning marketed by GreenEarth and PureGreen; and the new Class IIIA petroleum solvents plus wet cleaning. A fourth possible alternative using another petroleum-based solvent, propylene glycol ether, and marketed by Rynex, was not considered to be market-ready at this point. (The study group knows of only one Rynex plant in the United States that has operated for an extended period of time, but it apparently has been converted to some other process.) A fourth partial alternative, more wet cleaning, is also included in the study group’s analyses and recommendations. In addition to these alternatives, the opportunities for further reductions in current solvent usages were also evaluated.


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Master Matrix The approach of the study group was to develop a “Master Matrix,” Table 8, of the following key factors and business considerations for the two current and four potential new dry cleaning processes:

Equipment Financial Aspects Conversions Costs - solvents Solvents Costs - equipment % Wet Cleaning Costs - operating Processing Feasibility Aspects

Cycle times Costs - entry Training Costs - conversions Fabrics unable to process Profitability Cleaning performance Barriers - entry

Health and Environment Barriers - exit Toxicity Regulations Waste disposal Safety

From this master matrix, two conversion tables were developed to summarize the conversions to alternative processes. Table 5 summarizes the key factors for switching from PERC to each of five alternatives, including the alternatives of further reducing the usage of PERC and doing more wet cleaning. Table 6 summarizes the key factors for switching from Class II petroleum to each of five alternatives, including the alternatives of further reducing the usage of petroleum solvents and doing more wet cleaning. A Brief Overview of North Carolina’s Dry Cleaning Industry

More than 30,000 dry cleaning plants operate in the United States, with about 675 in North Carolina. Although North Carolina is the 12th largest dry cleaning market in the United States, North Carolina accounts for only about 3 percent of the nation’s dry cleaning sales. The North Carolina Association of Launderers and Cleaners (NCALC) (whose membership operates over 275 plants) estimates that 60-80 percent of North Carolina dry cleaners are very small, family-owned, single plant businesses, with the balance being multi-plant operations. These are basically operator-owned/family-run businesses with most of operator/family assets and savings tied-up in the business. As shown in the Master Matrix, profits vary with business volume, as would be expected. But one thing not shown in the Matrix is the long hours worked by family members, which equates to rather low hourly rates. Consequently, capital expenditures are very serious matters and can mean considerable risk well beyond the normal business concerns for a family. The types of processes in operation in 1997 are shown in Table 1 of the Trends section.


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Since about 1995, North Carolina’s dry cleaning industry has worked effectively with DENR, environmental groups and the North Carolina General Assembly to develop programs and legislation to reduce the likelihood of further contamination and to clean-up contaminated sites.

A Brief History of the United States and North Carolina Dry Cleaning Industries

Dry cleaning came to the United States from Europe. In the beginning, garments were disassembled and soaked in white gasoline, brushed with a rice root brush, dried, reassembled and pressed. Then came wooden rotating baskets half-filled with white gas, and the garments were no longer disassembled. Fires were common. The search for a less dangerous solvent led to the brief use of carbon tetrachloride, which was very toxic. The first Stoddard solvent was developed in 1932. Prior to World War II, centralized processing plants servicing small “pressing clubs” and routes did most of the cleaning in North Carolina. After the war a chemical that was being used in fire extinguishers, tetrachloroethylene (PERC), began to be used in the dry cleaning industry. This nonflammable solvent allowed dry cleaners to locate in neighborhoods and shopping centers, and was a more aggressive solvent that shortened the cleaning time. PERC started replacing Stoddard solvent, and also led to the myth of “one-hour dry cleaning.” In the mid ‘80s, chlorofluorocarbon solvents were temporarily used in some plants, but were discontinued due to their potential effects on ozone. The possible health impacts of PERC became better known in the ‘80s and ‘90s. In 1984, the first RCRA regulations were implemented to start addressing the groundwater contamination problem. In September 1993, the EPA promulgated a new national emissions standard for PERC dry cleaning, one of the first such standards issued under the Clean Air Act Amendments of 1990. This standard covered essentially all PERC dry cleaners and required them to control air emissions through the use of refrigerated solvent recovery facilities and various add-on devices, which have become known as the Generation 3 machines. These regulations have been effective in reducing water and air contamination. Most of the groundwater contamination appears to have taken place prior to the issuance of the RCRA regulations. The cleanup of these contaminated sites is not a subject of this study, as the Dry Cleaning Solvent Clean-up Act of 1997 covers that aspect. Concurrently, petroleum cleaning continued to be utilized for various cleaning situations. New Stoddard type solvents such as quick dry, naphtha and mineral spirits were developed, but they were all safety hazards due to their low flash points. Higher flash point solvents were introduced around 1995, and are gradually being used more and more in the industry. The EPA classifies these new solvents as nonhazardous, whereas the Stoddard class was classified as hazardous due to lower flash points. The fire regulations and equipment have been upgraded. The study group is unaware of any fires in the North Carolina dry cleaning industry in at least the past 10 years. This fine safety record and


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the use of higher flash point solvents have led to a better acceptance of these solvents by zoning and fire officials and the wider and easier placement of these processes. The development and field testing of two new dry cleaning processes, liquid carbon dioxide and cyclic siloxanes, has been led by two North Carolina companies: Micell-Hangers® and Medlin-Davis Cleaners. Labeling Dry cleaners do not control the types of clothes that are designed and manufactured, but they must clean all of them in an acceptable manner, within a reasonable time, and at a reasonable cost. The labels currently placed on garments are based on tests run in only PERC and Class II petroleum solvents. Thus, the success of alternative dry cleaning processes can be strongly influenced by the labels on garments. At this point, labels do not include cleaning with cyclic siloxanes, carbon dioxide or wet cleaning, so dry cleaners using these processes do so at their own risk. The U.S. FTC rule on labeling requires apparel items to have a permanent care label to provide information to consumers and professional cleaners specifying one acceptable care procedure. If professional cleaners fail to follow the care label instructions and damage a garment, they are legally responsible for that damage. Some changes in the labeling of garments could facilitate increasing the use of the alternatives, with a consequent further reduction in the use of solvents. This subject has had and continues to get a lot of attention at the international level, and thus this study group did not attempt to include it in this study. New test methods are being developed for the alternatives, and at some time in the future they may be included in the labeling of new textile products.

The Cleaning Process – Roles of Solvents, Detergents, Surfactants, and Moisture The cleaning process is a combination of at least three mechanisms:

1. the dissolution of soils in the solvent being used, 2. the solubilization of soils by the detergent and the moisture present in the system; 3. the physical removal of soils by mechanical action.

Moisture is needed at various levels in all the cleaning processes, including the solvent processes, and works in conjunction with the detergents.


14

Solvents have varying cleaning “powers.” None of them cleans everything by itself. A frequently used rating system of solvents is the KB Value (Kauri-Butanol), and the commonly used solvents have the following values:

KB Value PERC 90 Petroleum Class II 27-30 Petroleum Class IIIA 25-27 Cyclic Siloxanes 17 Liquid CO2 Less than 10

This system can be misleading and should not be used by itself to characterize a solvent. Various additives and operating variables improve the overall cleaning capability of each cleaning process. None of the current solvents, nor the new ones, are capable of dissolving and removing all of the soils on all of the garments. All of these use additives of various sorts to improve their cleaning process. These additives are frequently given various names such as detergents, surfactants, etc. But they are all added to dissolve and solubilize the soils, and consequently all are solvents to varying degrees. Thus, this study group views all of the materials used in each process as a combination of solvents, irrespective of their names. Some spotting solvents are hazardous materials, but are used in very small quantities, usually about one gallon over a period of 18 months per facility. Following are the primary quality concerns and causes of problems in the dry cleaning industry:

Shrinkage (dimensional stability) caused by excessive moisture (humidity), heat (drying and steam finishing), agitation, and drying to too low of a moisture level.

Wrinkles caused by high moisture content in the

solvent and too much time between the end of drying a garment and its pressing

Color fading/dye migration various dyes “bleed” when cleaned in

certain solvents, and various garments fade during cleaning. Excessive moisture and high heat contribute to this problem.

Damage to trim caused by agitation, heat and chemical

reaction.


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Redepositing of soils caused by poorly maintained solvent and poor moisture control due to reduced detergent levels,

Choice of materials/production these variables include soluble finishes, by garment manufacturers embossing, pleats, unserviceable dyes that

bleed, low-cost fusing/adhesives, fabric processed under tension, loose weaves, low twist yarns.

Simplified diagrams for the current and alternative processes are shown in Figs. 1 – 6.


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Listing & Tagging

Spotting

Cleaning Filtration Drying

Finishing Inspection Packaging Delivery

Classification Inspection

Drying

Fig. 1 PERC Dry-to-Dry Clothes

Detergents

PERC

Surfactants

Finishing Chemicals

Air Emissions

Separator Water

Spent Filters

Solvent Recovery Still

Resource Recovery

Evaporation

Still Residue


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Listing & Tagging

Spotting



Drying

Fig. 2 Petroleum Transfer Clothes

Detergents

Petroleum

Surfactants

Finishing Chemicals

Separator Water

Dry

Dry

W

ash

Air Emissions

Spent Filters


Resource Recovery

Evaporation

Still Residue


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Listing & Tagging

Spotting




Drying

Fig. 3 Petroleum Dry-to-Dry

Clothes

Detergents

Petroleum

Surfactants

Finishing Chemicals

Air Emissions

Separator Water

Spent Filters


Resource Recovery

Evaporation

Still Residue


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Listing & Tagging

Spotting




Drying

Fig. 4 Cyclic Siloxanes Dry-to-Dry Clothes

Detergents

Cyclic Siloxane

Surfactants

Finishing Chemicals

Air Emissions

Separator Water

Spent Filters

Fractional Distillation

Resource Recovery

Evaporation

Still Residue


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Listing & Tagging

Spotting




Drying

Fig. 5 Carbon Dioxide Dry-to-Dry Clothes

Detergents

Carbon Dioxide

Surfactants

Finishing Chemicals

Still Residue

Spent Filters

Detergents

Air Emissions


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Listing & Tagging

Spotting

Cleaning Finishing Inspection Packaging Delivery


Drying

Fig. 6 Wet Cleaning Clothes

Detergents

Water

Surfactants

Finishing Chemicals

Wastewater To City Wastewater Treatment Plant

Drying


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Trends in the Dry Cleaning Industry Solvent Usages, Equipment, Environmental Impacts, Safety

Following are data and comments on trends in the dry cleaning industry covering the usage trends of the current predominant solvents, upgrading of the machines, environmental impacts, safety aspects, acceptance of processes, and the additional use of wet cleaning. The dry cleaning industry has, of course, been under considerable pressure for the past few years to reduce its usages and emissions of solvents. Each of six processes is covered in the following order: Processes

A. PERC plus Wet Cleaning Each process section includes: B. Petroleum + Wet – Class II Solvents > Solvent Usages C. Petroleum + Wet – Class IIIA Solvents > Equipment D. Cyclic Siloxanes + Wet Cleaning > Environmental Impacts E. Liquid Caron Dioxide (CO2) + Wet > Safety Aspects F. Wet Cleaning > Acceptances of Processes

A. The PERC Process

1) Reduced Usage of the Solvent PERC and Process Efficiency a. PERC usage in the dry cleaning industry has dropped dramatically (by 75-

80 percent) since 1985, as shown in Fig. 7 at the end of this section. This reduction is probably due to a combination of several factors, such as people wearing more casual clothes and the dry cleaners becoming more efficient. However, major factors have countered the reduction, such as a growing population and more professional women in the workforce. This study group has not attempted to predict whether PERC usage will continue to decline, level off, or increase.

b. A key efficiency number used in this industry is – pounds of clothes

cleaned per gallon of PERC used (lbs/gal.) Table 1 shows that, on average, North Carolina PERC dry cleaners used 287 gal./yr. in 1997. The “average” PERC dry cleaner cleans about 78,000 lbs. of clothes per year. Thus, the PERC dry cleaners’ efficiency for 1997 was 272 lbs. clothes/gal. PERC. The North Carolina PERC process mix for 1997 was about 75 percent Generation 3, 15 percent Geneneration 4, and 10 percent transfers. Table 2 lists the various PERC machine generations.


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2) Potential Further Reductions in PERC Usage There are several possibilities for further efficiency improvements and reductions in the usage of PERC by further upgrading of machines, more training of operators and classifiers, and increased use of wet cleaning.

i. Industry usage numbers collected by The International Fabricare Institute (IFI) indicate Generation 4 efficiencies could be about 600 lbs/gal and perhaps higher depending on attainable machine schedules. A level of 600 is, of course, more than double the 1997 level of 272 in North Carolina, and if attained, would further reduce the usage of PERC by about 50 percent.

ii. With more effective training of the machine operators, PERC

usages could be reduced further.

iii. With more effective training of the classifiers in sorting garments and the purchase of new high-tech wet cleaning machines, more wet cleaning could be done, which would further reduce PERC usages. This study group estimates wet cleaning could be increased from the current 10 percent level to about 30 percent by purchasing new, high-tech washing and drying machines. With the purchase of additional specialized finishing equipment, the level of wet cleaning could be raised to nearly 70 percent. Labor costs could be higher, but solvent costs should be lower.

iv. The rising cost of PERC due to the solvent use tax implemented in

1997 has contributed to motivating many PERC dry cleaners to upgrade their old equipment and to become more efficient in their operations. The current regulations require all machines to meet at least the Generation 3 level, but new Generation 3 machines are no longer available for purchase. Consequently, there will be at least an “attrition” move to Generation 4. A Generation 5 machine is available which might reduce usages by about 10 more gal/yr. However, this machine costs an additional $10,000, increases the cycle time by 5-10 minutes, and raises operating costs. It has not been well received by the industry thus far. As mentioned above, IFI estimates Generation 4 machines could markedly raise the overall efficiency level of the industry.

One of the major sources of PERC losses has been the discard of spent cartridge/carbon filters used to clean the solvent as part of the normal machine operation. These losses account for about 27 percent (78 gal/yr.) of total losses. A new type of filter, the spin disk filter, has been introduced which essentially eliminates the solvent losses in the filtering process. However, these new filters


24

do not clean the solvent as well as the cartridge/carbon filters, so a reduction in the cleaning quality could result. Some dry cleaners are already buying the spin disk filters with new machines, but some would not be able to use them due to their special quality requirements. Existing machines could be converted to spin disks for about $4,500. Saving 78 gal/yr at a cost of $18/gal would be worth about $1,400/yr, which would give a pretty good return on investment (ROI). Another potential way to reduce solvent losses from cartridge/carbon filters may be to dry spent filters in the basket of the PERC machine before discarding. This would involve modifying the machine so the basket does not rotate during an otherwise standard drying operation. This procedure needs to be further tested to fully develop its feasibility. If successful, cartridge/carbon filters could become nearly as solvent efficient as spin disk filters.

3) Elimination of PERC “Transfer” machines

The 1997 survey of North Carolina dry cleaners (Table 1), lists about 70 PERC “transfer” operations out of a total of 675. These operations were large emitters of PERC, using about twice as much solvent as dry-to-dry machines. In 2001, there are essentially no transfer operations. In talking with many of those who converted their “transfer” operations, a major motivating factor was the higher cost of PERC, due in large part to the “solvent use tax” contained in prior legislation, bringing about a financial incentive for elimination of this type of operation.

4) Environmental Impacts of PERC a. Air Emissions

278 gal./yr. of PERC usage (’97 North Carolina average) is about 3,767 lbs./yr., BUT less than 30 percent of PERC usages get into the air, or less than 1,200 lbs./yr. By comparison:

i) The EPA de minimis level for PERC emissions to the air for the

wood furniture industry is 8,000 lbs./yr. per plant.

ii) The North Carolina Toxic program allows PERC emissions into the atmosphere of up to 13,000 lbs./yr. before requiring modeling to determine if the facility requires an air permit.

iii) The EPA has issued a MACT (Maximum Achievable Control

Technology) for all dry cleaners covering permitting requirements,


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record keeping and work practice standards. Dry cleaners who use less than 140 gal/yr are exempt from the MACT, but must still keep appropriate records.

iv) All PERC dry cleaners are scheduled to become Title Vs by Dec.

9, 2004, regardless of their emission rates. PERC is both a hazardous air pollutant and a toxic air pollutant in North Carolina. A facility normally must emit 10 tons/yr. of an individual hazardous air pollutant before it is required to obtain a Title V permit, which includes higher fees, considerable record keeping, and several work standards. The North Carolina toxic air regulations require a facility to do modeling at its property line if it emits over 13,000 lbs./yr. The modeling results are then compared to concentration limits at the property lines. A Title V permit in North Carolina currently costs $ 6,074/yr plus a tonnage fee.

b. Potential Groundwater Contamination

Potential groundwater contamination is also a major concern. Historically, potential groundwater contamination came from three sources: 1) the accidental release of PERC stored on the premises, such as a spill which gets into the ground; 2) the accidental release of PERC during the distillation of dirty PERC, i.e. a boil-over, which could also get into the ground; and 3) condensation of water during the dry cleaning process coming into contact with the PERC during normal cleaning operations, and subsequently discharged to a sewer, a septic system, or to a creek or lake. The majority of the contamination of groundwater probably occurred prior to the development of the environmental regulations.

For sources (1) and (2), North Carolina rules and regulations have already been tightened significantly so that there is little chance of more PERC getting into the groundwater or surface waters. These improvements were developed jointly by the N.C. General Assembly, DENR, environmental groups and NCALC.

To further protect against possible contamination from sources (1) and (2), secondary containment, transferring PERC in closed containers only, and the prohibition of underground PERC tanks become mandatory for all dry cleaning operations Jan. 1, 2002.

For source (3), PERC has a low solubility in water, but this “contact/separator water” does retain a small amount of PERC, in the 3-300 ppm (parts per million) range, depending on equipment age. The presence of PERC in this “contact water” makes this water a RCRA hazardous waste that must be handled in special


26

ways. Most North Carolina dry cleaners either have this contact water carried away by a hazardous waste hauler or they filter and evaporate the water and PERC on-site as approved by EPA.

North Carolina regulations are stricter than the federal regulations in that North Carolina dry cleaners are not permitted to discharge any contact water to the sewer (15A2S.0202(b)(1), septic tanks or ground, whereas the U.S. EPA permits dry cleaners to discharge contact water to the sewer. However, local wastewater treatment plant managers can override these national rules.

A Perspective Point - the amount of PERC contained in all the separator/contact water from a single PERC machine for an entire year is less than 1 lb.

5) Safety Aspects of the PERC Process

PERC is not a potential fire hazard because it does not burn. The process operates at atmospheric pressure.

This process requires heat, which is usually supplied by an on-site boiler.

6) Acceptance of the PERC Process

The general public has accepted this process. It is an excellent solvent, can be utilized safely on most garments, and allows the dry cleaner to offer fast turn-around.

Findings – PERC:

1) PERC usages have been reduced 75-80 percent over the past 15 years. Usage can probably be further reduced by improving the efficiency of operations, installing more Generation 4 machines, raising the amount of wet cleaning, and perhaps by replacing cartridge/carbon filters with spin disk filters. The 1997 efficiency of 272 lbs/gal was not quite half of IFI’s projected efficiency of 600 lbs/gal for well-run Generation 4 machines.

2) Much of the PERC lost in the processing of clothes is lost in the spent

cartridge/carbon filters and the still residues. Using the new spin disk filters where feasible will reduce these loses. There may also be potential to further reduce losses from cartridge/carbon filters by an in-situ procedure that needs further evaluation.


27

3) Many North Carolina PERC dry cleaners have upgraded their machines or bought new machines. In 1997, about 70 PERC transfer operations existed; today there are few, if any.

4) Professional wet cleaning is used for only about 10 percent of the total

cleaning demand.

5) PERC machine air emissions are small compared to other prevalent industries. However, each dry cleaning establishment could become a Title V facility by Dec. 9, 2004, and be required to pay an annual permit fee of over $6,074.

6) The potential for future groundwater contamination with PERC appears to be

very low due to the changes in dry cleaning operations and the regulations developed over the past several years. Most of the contamination of groundwater was apparently done prior to the development of environmental regulations. Additional requirements (MMPs) will become effective Jan. 1, 2002, which should further reduce the likelihood of contaminating the groundwater.

7) The PERC process is relatively safe in that it is not a fire hazard.

Recommendations - PERC:

1) The PERC dry cleaners should be commended for their contributions to

reducing the usage of PERC by about 75 percent over the past 15 years. 2) The dry cleaners should be encouraged to further reduce their PERC usages,

with a target of improving their efficiencies to about 600 lbs. clothes/gal. PERC.

3) Encourage the upgrading of equipment from Generation 3 to at least

Generation 4. Include the capital monies spent to upgrade PERC equipment along with the other alternatives in any financial incentives provided.

4) If all North Carolina PERC dry cleaners become Title V facilities, encourage

North Carolina DENR Division of Air Quality (DAQ) and the Environmental Management Commission (EMC) to develop permit procedures, if possible, to reduce the Title V annual permit fee, currently $ 6074 plus a small emissions-based fee. Such an annual permit fee would be a substantial per cent of a small dry cleaner’s annual profit. If possible, include incentives to reduce the usages of PERC.

5) The handling and discarding of spent PERC and separator/contact water

should not be relaxed for North Carolina dry cleaners, even though less stringent federal and state regulations exist elsewhere.


28

6) Continue the privilege/excise tax on the purchase of PERC and use it to fund

the Dry Cleaning Solvent Cleanup Program.

7) Fund experiments on dry-to-dry machines with cartridge/carbon filters to determine if these filters can be dried effectively in-situ.

8) Encourage increased use of professional wet cleaning.

9) Encourage NCALC and other appropriate organizations to provide more

training in the most efficient operation of the entire process.

Legislation Proposals - PERC: 1) Establish a financial aid program to assist dry cleaners with the acquisition

and installation of Gen 4 and Gen 5 PERC systems, and the purchase and effective use of more professional wet cleaning equipment.

Since the majority of North Carolina dry cleaners are small businesses, the preferred hierarchy of financial assistance is: 1) grants, 2) low interest guaranteed loans, and 3) tax credits. The amount of assistance should be based on the level of operator training and the use of professional wet cleaning.


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B & C. Petroleum Processes – Class II and Class IIIA

Both transfer and dry machines are used in these processes. The classes of petroleum solvents and their corresponding equipment are shown in Table 4. This group of solvents includes: 1. Class II petroleum solvents, which are the Stoddard solvents that have

been used since 1932. The EPA classifies these solvents as hazardous materials because their flash points are below 140 °F. They also contain some known toxic chemicals, but are not classified as toxic.

2. New Class IIIA petroleum solvents have higher flash points, contain

essentially no toxic chemicals, and are not classified as hazardous materials due their flash points being above 140 °F.

1) “Old” Petroleum Solvents – Class II, Flash Points Less than 140 °F The mix of petroleum solvent usages for 1997 in North Carolina is shown in Table 3 for the 136 petroleum operations registered with DAQ Central. Note the 174,856 gallons of petroleum solvents used, compared to the 153,835 gallons of PERC shown in Table 1. Most dry cleaning, as measured by pieces or pounds, is done with PERC, so it might have been expected that the larger gallon usage would have been PERC. The use of more gallons of petroleum solvents manifests its lower efficiency and the stronger cleaning power of PERC for many garments. The efficiency of Class II petroleum solvents is about 175 lbs/gal.

2) “New” Petroleum Solvents – Class IIIA, Flash Points Above 140 °F To meet the zoning requirements for siting petroleum processes in various areas of a community, and to reduce the amounts of toxic aromatics, the petroleum industry developed a new group of solvents that carry trade names such as Exxon DF 2000 (flash point 147 °F), Shell 140 (flash point 145 °F), etc. The new Class IIIA petroleum solvents have flash points somewhat above the 140 °F threshold, and they also appear to contain very little of the toxic, aromatic chemicals of major concern. These solvents work well in both transfer and dry machines, but have lower solvent power and require longer cleaning and drying cycles. The efficiency of Class IIIA solvents is about 175 lbs/gal. With their marginally higher flash points, they avoid classification as hazardous materials by the EPA, but are hazardous


30

materials by OSHA standards. They still light off and burn very well, and therefore must still be considered fire safety hazards.

3) Potential Further Reductions in Petroleum Usage

i. It is estimated that about two-thirds of the 148 petroleum

operations shown in Table 1 are transfer operations. The primary solvent loss for this type of operation is not so much in the transferring of clothes from the washer to the dryer, but mostly in the drying part of the operation. For many years, the solvent dried out of the clothes was vented to the atmosphere. New cooled dryers reclaim the solvent and have significantly reduced petroleum emissions - by 85-90 percent. These new dryers have reduced petroleum solvent usages to about 600 gal./yr., down from about 4,000 gal./yr. just a few years ago, and have produced a very good return on investment (ROI). DPPEA assisted one North Carolina dry cleaner with the purchase and evaluation of these new dryers.

ii. With more effective training of the classifiers in sorting

garments, along with the purchase of the new high-tech wet cleaning machines, more wet cleaning could be done, which would further reduce petroleum usages. This study group estimates wet cleaning could be increased from the current 10 percent level to about 30 percent by purchasing new, high-tech washing and drying machines. With the purchase of additional specialized finishing equipment, the level of wet cleaning could be raised to nearly 70 percent. Labor costs could increase, but solvent costs would be lower.

4) Environmental Impacts of Petroleum Processes

a. Air Emissions

i) Stoddard solvent is neither a hazardous air pollutant nor a toxic air pollutant.

ii) The new cooled dryers use about 600 gal./yr., down from about

4,000 gal./yr. Six hundred gallons is about 3,600 lbs. Most of the solvent is lost in the filters and still residues.

iii) Part JJJ of the Federal New Source Performance Standards

(NSPS) regulations covers petroleum dry cleaners. If a plant has equipment that can hold more than 84 lbs. of clothes, it is subject to this regulation, which requires certain testing of its


31

vent stack. Additionally, North Carolina has a regulation that requires dry cleaners covered by JJJ to obtain a North Carolina air permit.

b. Potential Groundwater Contamination

Potential groundwater contamination is also a concern. Historically, potential groundwater contamination came from three sources: 1) the accidental release of petroleum solvent stored on the premises, such as a spill which gets into the ground; 2) the accidental release of petroleum solvents during the distillation of dirty solvents, i.e. a boil-over, which could also get into the ground; and 3) condensation of water during the dry cleaning process coming into contact with the petroleum solvent during normal cleaning operations, and subsequently discharged to a sewer, a septic system, or to a creek or lake. The majority of groundwater contamination occurred prior to the development of environmental regulations.

For sources (1) and (2), North Carolina rules and regulations have already been tightened significantly so that there is little chance of additional petroleum solvents getting into the groundwater or surface waters. These improvements were developed jointly by the North Carolina General Assembly, DENR, environmental groups, and the dry cleaning industry, led by NCALC.

To further protect against possible contamination from sources (1) and (2), secondary containment and a ban on underground storage of petroleum solvents becomes mandatory for all dry cleaning operations effective Jan. 1, 2002.

For source (3), the petroleum processes generate “separator/contact water” similar to the PERC processes. Though this water is not a hazardous waste, North Carolina petroleum dry cleaners are subject to the same restrictions as for PERC (15A2S.0202(b)(1), and therefore cannot discharge to a sewer, septic systems, surface waters, nor the ground. They either filter and evaporate it on-site or dispose of it via a waste hauler.

5) Safety Aspects of Petroleum Solvents and Processes

The petroleum Class II solvents have been considered fire safety hazards for many years, so much so that zoning laws were enacted to keep them out of certain areas. The new NFPA 32 fire code requires better firewalls, automatic sprinklers and systems to significantly reduce the likelihood of an explosive mixture being present. Many existing petroleum dry cleaning plants have been in existence for a number of years, and were


32

“grandfathered” into local fire codes. This study group is not aware of any fires in the North Carolina petroleum dry cleaning plants for at least the past 10 years.

The new Class IIIA petroleum solvents have marginally higher flash points, but must still be considered fire safety hazards. The local fire marshals are usually very strict about following these codes.

6) Acceptance of Petroleum Process

The Class II petroleum processes have been in operation for more than 100 years, and are well accepted by the public and the dry cleaning industry. The Class IIIA process has been in operation for a few years, and is also well accepted.

Findings – Petroleum(s): 1) The Class II petroleum process involves a hazardous material; the Class IIIA

petroleum process does not involve a hazardous material.

2) The use of petroleum solvents in the transfer process has been reduced about 90 percent for those who have installed solvent recovery dryers. This investment has produced a good return on investment (ROI).

3) Although the Class IIIA solvents have higher flash points than those of Class

II, the Class IIIA solvents are still fire safety hazards and are still hazardous materials by OSHA standards.

4) Petroleum dry cleaners covered by Part JJJ of the Federal NSPS regulations

must obtain a North Carolina air permit. NC DENR Air Quality (DAQ) is working with the NC Environmental Management Commission (EMC) to rescind this requirement.

5) The new NFPA 32 fire code requires the use of additional safety features that

significantly reduce the likelihood of an explosive mixture being present in the process. The study group does not know of any fires in the North Carolina petroleum dry cleaning industry during the past 10 years.

6) Professional wet cleaning is used for only about 10 percent of the total

cleaning demand.


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Recommendations – Petroleum(s): 1) Commend those petroleum dry cleaners that have installed the solvent

recovery dryers and have reduced their emissions by about 90 percent.

2) Encourage all transfer petroleum dry cleaning operations, existing and new, to install cooled solvent recovery dryers.

3) Encourage conversion to the Class IIIA petroleum solvent process.

4) Encourage increased use of professional wet cleaning.

5) The NC DAQ and EMC complete the rescission of the requirement for

petroleum dry cleaners subject to NSPS JJJ to acquire a NC air permit.

6) Although the contact/separator water from petroleum operations is not a hazardous waste, continue to prohibit disposal to a sewer, septic tank or surface waters. Allow it to be filtered and then evaporated and/or atomized, as well as disposed as a hazardous waste.

7) Continue the privilege-excise tax on petroleum solvents, and use it to fund the

Dry Cleaning Solvent Cleanup Program. Legislation Proposals – Petroleum(s):

1) Establish a financial aid program to assist dry cleaners with the acquisition

and installation of solvent recovery dryers, dry-to-dry petroleum systems utilizing Class IIIA solvents, and increased professional wet cleaning. Since the majority of North Carolina dry cleaners are small businesses, the preferred hierarchy of financial assistance is: 1) grants, 2) low-interest guaranteed loans, and 3) tax credits. The amount of tax credits should be based on the level of operating training and the use of wet cleaning.

2) Repeal the requirement for North Carolina dry cleaners covered by Part JJJ of

the NSPS regulations to obtain a North Carolina air permit.


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D. Cyclic Siloxanes

1) Solvents

The cyclic siloxane process is being marketed under the name GreenEarth, who has provided most of the information on this process to this study group. Additional companies, such as PureGreen, may be coming into the market. The main solvent is not classified as a hydrocarbon, but is listed as a hazardous material on the MSDS sheets, it does burn, and it has a flash point of about 170 °F. In addition to its base silicon structure, it contains hydrocarbon components and requires additional detergents in order to clean all types of garments. Better systems of cyclic siloxanes and detergents are still under development. The relative efficiency of this process has not yet been established in lbs/gal.

2) Cyclic Siloxane Machines

The cyclic siloxane process uses essentially the same equipment as the Class IIIA petroleum dry-to-dry process, with the addition of a fractional distillation unit. The GreenEarth company insists a dry cleaner buy a new stainless steel machine, and not convert an existing petroleum machine.

3) Environmental Aspects of Cyclic Siloxanes

The EPA is still evaluating cyclic siloxanes, but one set of test results the study group has seen suggests it is not toxic. This family of solvents has been used in the personal care field for years and has been tested extensively by other agencies. The EPA air quality section has determined that these compounds are not hazardous air pollutants, nor are they VOCs. However, the primary solvent and the added detergent are hazardous materials by OSHA standards, according to their MSDS sheets. But they appear to not be hazardous materials by EPA standards.

4) Safety Aspects of Cyclic Siloxanes

This solvent burns and has a flash point above 140 °F which makes it a Class IIIA solvent. It is a fire safety hazard. This process requires heat, so it has a boiler on-site.

5) Acceptance of Cyclic Siloxane Process As of this study, GreenEarth reports having sold over 130 processes using cyclic siloxanes in the United States since its introduction in 1999. It is too early to draw any conclusions on its acceptance by the general public.


35

Findings – Cyclic Siloxanes:

1) This process appears to be feasible when supplemented with wet cleaning like the current processes. It has not been used long enough to gauge public acceptance.

2) It uses essentially the same equipment as the dry-to-dry petroleum process. 3) Although this solvent is not a hydrocarbon by the technical definition, it is a

Class IIIA solvent, a potential fire safety hazard, and a hazardous material according to its MSDS sheet.

Recommendations – Cyclic Siloxanes:

1) Encourage the further commercial use of this process.

Legislation Proposals – Cyclic Siloxanes:

1) Establish a financial aid program to assist dry cleaners with the acquisition and installation of the cyclic siloxane processes and more professional wet cleaning. Since the majority of North Carolina dry cleaners are small businesses, the preferred hierarchy of financial assistance is: 1) grants, 2) low-interest guaranteed loans, and 3) tax credits. The amount of tax credits should be based on the level of operating training and the use of wet cleaning.


36

E) Liquid Carbon Dioxide

1) Solvent The liquid carbon dioxide processes are marketed under the names of Micell-Hangers® (MiCare/Hangers), Chart, SailStar, Alliance (DryWash), and perhaps others. Micell appears to have been the leader for this new process, and most of what the study group has learned about this process is based on the Micell process. Since CO2 is a weak solvent, Micell and perhaps the others, supplement the base solvent with a proprietary detergent mixture containing hydrocarbon chemicals in order to dissolve certain soils. This solvent system thus far has had to be supplemented with wet cleaning and one or more of the current dry cleaning processes, or supplemented with outsourcing. It is consequently not a complete alternative to the current processes at this time. The developers continue to pursue improving the detergent and CO2 mixtures. The relative efficiency of this process has not yet been established.

2) Carbon Dioxide Machines

The CO2 process operates at high pressures, in the range of 750-800 pounds per square inch (psi). The machines are built of heavy steel and are very different from the current machines.

3) Environmental Aspects of CO2

CO2 is the same chemical that power companies are being forced to reduce. However, the use of CO2 in this process should not be viewed as contributing to global warming, as it does not generate CO2; it only uses some of what has been taken out of the atmosphere, and then returns it to the atmosphere.

The detergent mixture that supplements CO2 in the Micell process is a hydrocarbon compound with a flash point above 140 °F, and it burns. Thus it is a Class IIIA solvent, but is not classified as a hazardous material by the EPA. However, it is a hazardous material by OSHA standards. Micell requires its franchisees to recycle this material through Micell.

4) Safety Aspects of CO2

CO2 is a gas at room temperature and pressure. In order to transform it into a liquid state, it must be pressurized to the 750 – 800 psi range. To contain this high pressure, the equipment is built of heavy steel. If seals were to come loose, or various parts of the piping system were to come loose, they could become dangerous projectiles. Appropriate precautions should be taken.


37

If a “lot” of CO2 were emitted into a closed work area, it could create a dangerous atmospheric situation for anyone in the immediate area. Work areas need to be carefully vented to prevent such a build-up. This process does not use heat, but a boiler is located on-site for finishing operations.

5) Acceptance of Liquid CO2

As of this study, we have reports of 30-35 CO2 machines operating in the United States. It is too early to draw any conclusion about its acceptance by the general public.

Findings – CO2:

1) This process appears to be feasible when supplemented with wet cleaning and

either a solvent process or outsourcing. It has not been used long enough to gauge public acceptance.

2) This process operates at a high pressure (750-800 lbs./sq. in.), and is quite

different from current dry cleaning equipment. 3) The detergent mixture used with at least one of the CO2 processes is a

hydrocarbon compound. It is not a hazardous material by EPA standards, but is by OSHA standards.

4) While the CO2/detergent mixture is probably not a safety hazard, the detergent

mixture by itself is a Class IIIA solvent and is a fire safety hazard.

Recommendations – CO2:

1) Encourage the further commercial use of this process.

Legislation Proposals – CO2: 1) Establish a financial aid program to assist dry cleaners with the acquisition

and installation of the liquid carbon dioxide processes, and more professional wet cleaning. Since the majority of North Carolina dry cleaners are small businesses, the preferred hierarchy of financial assistance is: 1) grants, 2) low-interest


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guaranteed loans, and 3) tax credits. The amount of tax credits should be based on the level of operating training and the use of wet cleaning.

F. Professional Wet Cleaning

This process, sometimes erroneously called washing, was of course the first cleaning process. Professional wet cleaning has always been used by professionals in conjunction with the solvent processes, and is also being used in conjunction with the new processes being developed. The reason for using this process is that none of the solvents remove all types of soils and stains, so water is needed to remove those soluble in water. Some dry cleaners view it as a special spotting/stain removal procedure to be followed by solvent cleaning. Much of it has been done in sinks, buckets, etc. But despite where it has been done, professional wet cleaning has been a very skilled operation involving strict controls for temperature, pH, mechanical action, time, extraction and drying. The public is probably unaware of this aspect of cleaning.

1) New Wet Cleaning Detergents and Machines

Major improvements have recently been made in the detergents and machines used for wet cleaning to automatically control the important factors. Consequently, the potential exists today to wet clean a much higher percentage of all clothes. DPPEA assisted one North Carolina dry cleaner with the purchase and evaluation of one of these new systems, which has been very successful and is increasingly used.

2) Potential for More Wet Cleaning

Currently, 10 percent or less of all cleaning is done using the wet process in conjunction with both PERC and petroleum processes. Both GreenEarth and Micell are experiencing about the same percentage of wet cleaning with their new processes. A few dry cleaners (one in North Carolina with some grant help from DPPEA), have successfully increased this percentage using the new machines and dryers. One of the biggest barriers to doing more wet cleaning is the potential liability to the dry cleaner for using the wet process when the garment label specifies dry cleaning. If the garment is ruined during wet cleaning, the dry cleaner must pay to replace the garment and will also suffer damage to its reputation. The dry cleaners in the study group feel the usage of wet cleaning could be raised to about the 30 percen

north carolina department of environment and natural ...figure 4 cyclic siloxane dry-to-dry process...

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