In September 1993, the United States Environmental Protection Agency (U.S. EPA) promulgated national emission standards for hazardous air pollutants (NESHAP) for the perchloroethylene (PCE) dry cleaning process to control PCE air emissions from dry cleaners. This NESHAP requires dry cleaners to take pollution prevention (P2) steps to limit PCE emissions from both existing and new dry cleaning facilities.

Improved work practices: Once implemented, a number of work practices can reduce PCE losses. These include:

• Maintaining proper reclamation time to ensure that solvents are not lost during aeration;
• Weighing clothes to ensure that machines are not overloaded;
• Operating the equipment at the proper drying time to ensure that the least amount of solvent remains in the clothing;
• Monitoring the drying temperature to ensure that the maximum amount of solvent is removed from the clothing;
• Removing shoulder pads from garments whenever possible to limit the amount of solvent absorbed into the clothing; and
• Using log sheets to predict proper drying times by noting the trends in the weight of the load, the type of clothing, and drying times.

Monitoring: Monitoring of refrigerated condensers, carbon adsorbers and other control technology will help enable operators to ensure equipment is managed according to manufacturers' instructions.

Record keeping: Maintaining records of solvent usage and purchases and leak inspection and repair schedules will aid in management planning and equipment maintenance. Increases in the monthly amount of PCE used without corresponding increases in the number of loads washed may indicate solvent losses that can be investigated and controlled.

Leak detection and repair program:According to one estimate¹, up to 25 percent of solvent emissions can be attributed to equipment leaks. Facilities can identify problem releases efficiently by implementing a leak detection and repair (LDAR) program. The LDAR will enable facilities to check for leaks by sight (visual inspection to check for pools or droplets of liquid), smell (odor of PCE), and touch (manual detection of gas flow over the surface of the equipment or with the help of a halogenated hydrocarbon detector). The Dry Cleaning NESHAP requires that the following components be inspected at least every other week, although dry cleaning facility operators may want to conduct weekly inspections:

1. Hoses, pipe connections, fittings, couplings, and valves
2. Door gaskets and seatings
3. Filter gaskets and seatings
4. Pumps
5. Solvent tanks and containers
6. Water separators
7. Muck cookers
8. Stills
9. Exhaust dampers
10. Diverter valves
11. Cartridge filter housings

All leaks found should be repaired within 24 hours. A training program to implement the LDAR program fully should include proper equipment monitoring procedures and instruction on the proper use of leak detection equipment.

The compliance benefits listed here are only meant to be used as a general guideline and are not meant to be strictly interpreted. Actual compliance benefits will vary depending on the factors involved, e.g., the amount of workload involved.

• Implementation of this P2 options can be accomplished with minimal disruption of dry cleaning operations.
• Implementation and operating costs are minimal.
• Implementation of this P2 option will help the facility comply with the requirements of the Perchloroethylene Dry Cleaning NESHAP.
• Reduced PCE losses will decrease the amount of new PCE to be purchased.
• Worker exposure to PCE is reduced.

• Operators must be trained in proper leak detection techniques and in how to use leak detection equipment.

Assumptions:

• Dry cleaning machines included three dry-to-dry machines equipped with condensers, vapor recovery systems, and other control technology with an average load of 70 pounds of clothing per machine.
• Fugitive air emissions (1994) were 20,100 pounds (about 130 gallons).
• Air emissions reductions: Control of air emissions from equipment leaks can reduce emissions by 25 percent per year or approximately 5,025 pounds per year.
• Capital Costs: Leak detection equipment was available.
• Training: Two employees receive 16-hour training twice per year, for a total of 64 hours per year.
• Labor Rate: $20/hr
• Labor costs: Two hours of additional labor per week is required to implement improved work practices, and two hours of additional labor per week to implement the LDAR program.
• Equipment repair costs: The analysis assumes an average of 12 leaks detected per year and repaired in-house with an average repair time for in-house leaks of 1 hour. Parts are assumed to cost $25. In addition, an average of 1 leak per year is assumed to be detected that requires the services of an outside contractor. The average repair time for contractor repairs is assumed to be three hours; the part costing $200, and the labor rate is assumed to be $40/hour).
• Materials savings: Approximately 175 gallons of PCE were purchased per month in 1995; the cost of PCE (1995) is $4.99 per gallon; and materials savings from PCE purchases should total 43.75 gallons (25 percent of 175 gallons) per month.

Cost Analysis for Implementing Improved Work Practices and LDAR Program vs. Lack of Improved Work Practices and LDAR Program

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