State of California
AIR RESOURCES BOARD
Mark Hopkins Hotel
Room: Peacock Court
California and Mason Streets
San Francisco, CA
September 25, 1980
80-19-1 Public Meeting to Discuss State Policy for the
Disposal of Polychlorinated Biphenyls (PCB's).
80-19-2 Public Meeting to Consider Suggested Control 001
Measure for the Control of Volatile Organic Emissions
from Perchloroethylene Dry Cleaning.
80-19-3 Other Business
a. Executive Session
b. Research Proposals
c. Delegations to Executive Officer
ITEM NO.: 80-19-2
Suggested Control Measure for the Control of Volatile Organic
Emissions from Perchloroethylene Dry Cleaning Operations.
SUMMARY AND STATEMENT OF REASONS FOR SUGGESTED CONTROL MEASURE
The California Air Resources Board (ARB) is considering approval
of a suggested measure for the control of volatile organic
compound (VOC) emissions from perchloroethylene dry cleaning
operations. If approved by the Board, the suggested control
measure will be forwarded to appropriate air pollution control
measure will be forwarded to appropriate air pollution control
districts (APCDs) for consideration as amendments to their rules
and regulations to the extent necessary to provide for attainment
and maintenance of state and national ambient air quality
standards for oxidant and ozone, respectively. The proposed
control measure will establish a guideline as well as a technical
basis for local district consideration; however, it will become
an enforceable regulation only after it is adopted into the rules
and regulations of a district. Approval by the Board of the
proposed control measure does not create an enforceable
regulation which would be legally binding on the
perchloroethylene dry cleaning industry.
Currently, the state and national ambient air quality standards
for oxidant and ozone are violated in most urban areas of the
state. Perchloroethylene dry cleaning operations within these
areas emit perchloroethylene in significant amounts during the
cleaning and drying of clothing, disposing of solvent filters,
and other processes of the dry cleaning operations. The
emissions of perchloroethylene into the atmosphere from these dry
cleaning facilities contribute to the occurrence of complex
photochemical reactions which result in the formation of a
variety of atmospheric photochemical oxidants, including ozone.
The Federal Clean Air Act requires that states attain and
maintain the national ambient air quality standards for ozone.
The California Health and Safety Code requires that local APCDs
endeavor to achieve and maintain state ambient air quality
standards, including the standard for oxidants.
The staff of the Bay Area Air Quality Management District
(BAAQMD) in cooperation with the ARB, Environmental Protection
Agency (EPA) and other APCDs, has developed a suggested measure
for the control of emissions from perchloroethylene dry cleaning
operations. The background information used to develop this
suggested control measure includes the following: information
from BAAQMD, including the BAAQMD staff report; information from
EPA, including the Control Techniques Guideline (CTG) for Control
of Volatile Organic Emissions from Perchloroethylene Systems;
information collected by the ARB staff during visits to dry
cleaning operations; information published in the Federal
Register; ARB emission inventory data (which reflect data
obtained from the APCDs); and other information cited or reported
in the ARB staff report.
The ARB staff report and the above referenced documents are
available for public inspection at, and the staff report may be
obtained from, the Air Resources Board Public Information Office,
1102 Q Street, Sacramento, CA 95814 on or after August 8, 1980.
Emission control technology currently available for the control
of emissions from perchloroethylene dry cleaning operations
includes carbon adsorbers and vapor condensers. Carbon
adsorption controls, which are acceptable to the EPA, ARB,
BAAQMD, and the other APCDs, have been found to be reasonably
available to control this source of emissions. Vapor
condensation control equipment is also available for efficient
control of perchloroethylene emissions. Both of these controls
allow or capture and reuse of the perchloroethylene solvent.
Considering the present cost of perchloroethylene, approximately
$3.50 per gallon, the cost-effectiveness for control is estimated
to range between $0.19 (savings)/lb reduced for larger industrial
dry cleaners to $0.50 (cost)/lb for the smallest facilities which
are subject to controls for this measure (320 gallons per year
facility). These costs are based on EPA and BAAQMD economic
evaluations of sample dry cleaning operations. The ARB staff has
confirmed these cost-effectiveness estimates and concurs with
The statewide estimate of emissions from perchloroethylene dry
cleaning operations is 48 tons per day (based on ARB's 1979
emission estimates). An overall emission reduction of about 50
percent is expected from the existing, uncontrolled
perchloroethylene dry cleaners upon implementation of this
suggested control measure by the districts. Most of the sources
in this category are located in the Bay Area and the South Coast
Air Quality Management Districts.
The proposed measure would require that all drying tumblers and
cabinets be vented to a carbon adsorber or other control device
operating at a 90 percent minimum efficiency (by weight) or
controlled to a level of 100 ppm (by volume) during the entire
drying cycle (before dilution). This provision of the suggested
control measure will apply to dry cleaning operations consuming
more than 320 gallons of perchloroethylene per year. Dry
cleaning establishments which consume less than 320 gallons of
perchloroethylene per year would be exempt from these
requirements due to the relatively poorer const-effectiveness
anticipated for reducing emissions from these smaller operations.
Coin operated cleaners (coin-ops) also would be exempt from the
provision requiring installation of emission control devices.
The proposed measure would further require that all dry cleaning
operators immediately repair all perchloroethylene solvent leaks
from their equipment. In addition, all perchloroethylene-laden
waste would have to be stored in sealed containers. Final
disposal of such waste is already governed by State law.
Used filtration cartridges would have to be stored for 24 hours
in the filter cartridge housing or vented to the control device
for a 12 hour period. Diatomaceous earth filters would have to
be cooked or treated so that no more than 0.25 kg. of solvent per
kg. of wet waste remains. The measure would also require that
perchloroethylene solvent distillation residue contain not more
than 0.6 kg. of solvent per kg. of wet waste.
The principal environmental effect of this measure would be a
definite benefit to ambient air quality due to a reduction of
atmospheric perchloroethylene emissions. No significant adverse
environmental impacts of this measure have been identified.