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Training Program for Perchloroethylene Dry Cleaning Operations

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Training Program for Perchloroethylene Dry Cleaning Operations CURRICULUM FOR THE ENVIRONMENTAL TRAINING PROGRAM FOR PERCHLOROETHYLENE DRY CLEANING OPERATIONS State of California California Environmental Protection Agency Air Resources Board Stationary Source Division April 1996 [Blank Page] State of California California Environmental Protection Agency Air Resources Board Stationary Source Division P.O. Box 2815 Sacramento, California 95812 CURRICULUM FOR THE ENVIRONMENTAL TRAINING PROGRAM FOR PERCHLOROETHYLENE DRY CLEANING OPERATIONS April 1996 Primary Authors Tina Najjar Mark Williams Contributors Richard Boyd Victor Douglas Kelly Hughes Reviewed and Approved By Robert D. Fletcher, Chief, Emissions Assessment Branch Todd S. Wong, Manager, Emissions Evaluation Section [Blank Page] Acknowledgments We wish to acknowledge the participation and assistance of the dry cleaning industry and allied trade representatives, district and State agency staff, and others. We thank the many dry cleaners who have taken the time to show us their operations, participate in meetings, and respond to our requests for information. We wish to express a special appreciation to the dry cleaners who reviewed this document and provided constructive comments. Disclaimer This curriculum has been reviewed by the staff of the California Air Resources Board and approved for publication. Approval does not signify that the contents necessarily reflect the views and polices of the Air Resources Board, nor does mention of trade names or commercial products constitute endorsement or recommendation for use. [Blank Page] TABLE OF CONTENTS Chapter Page Information for Instructors v 1 Introduction A. Summary 1-1 B. The Regulations 1-1 C. Purpose of the Program 1-2 D. History of Dry Cleaning Solvents 1-3 2 Health Effects of Perchloroethylene A. Summary 2-1 B. ARB's Identification of Perc as a Toxic Air Contaminant 2-1 C. Perc Threshold Level 2-2 D. Potential Health Effects Associated with Perc Exposure 2-3 E. Potential Health Risks from Perc Dry Cleaning Operations 2-3 3 Perchloroethylene Usage and Emissions A. Summary 3-1 B. Properties of Perc 3-1 C. Perc Usage in California 3-2 D. Existing Emissions from Perc Dry Cleaning Operations 3-2 E. ARB's Survey of Dry Cleaners 3-4 F. Post-Implementation Emissions Reduction 3-5 4 Working with Perchloroethylene A. Summary 4-1 B. Material Safety Data Sheet 4-1 C. Signs of Excessive Exposure to Perc 4-3 D. Ventilation 4-5 E. Personal Protective Equipment 4-6 5 Dry Cleaning Equipment and Operations A. Summary 5-1 B. Dry Cleaning Process 5-2 C. Machine Types 5-2 D. Primary Control Devices 5-5 E. Secondary Control Devices 5-7 i 5 Dry Cleaning Equipment and Operations (cont.) F. Solvent Filtration 5-8 G. Distillation: Stills and Muck Cookers 5-10 H. Miscellaneous Equipment and Operations 5-11 6 The ARB's Dry Cleaning ATCM A. Summary 6-2 B. BACT for Dry Cleaning Equipment 6-2 C. Dry Cleaning ATCM Requirements 6-3 D. Equipment Requirements 6-3 E. Good Operating Practices 6-6 F. Recordkeeping and Reporting Requirements 6-8 G. District Requirements 6-16 H. Differences Between the Federal Dry Cleaning MACT Standard and the Dry Cleaning ATCM 6-16 7 Operations And Maintenance Practices A. Summary 7-1 B. General Operations 7-2 C. Required Routine Maintenance 7-2 D. Recommended Routine Maintenance 7-5 E. Waste Handling 7-10 F. Operations and Maintenance Checklist 7-11 8 Leaks and Leak Detection A. Summary 8-1 B. Leaks 8-2 C. Halogenated-hydrocarbon Detector 8-6 D. Leak Checklist 8-8 E. Service and Repair Log 8-12 9 Spills and Emergency Response A. Summary 9-1 B. Spills 9-2 C. Spill Prevention Techniques 9-3 D. Emergency Action and Contingency Plans 9-4 10 Other State and Local Regulations A. Summary 10-2 B. Department of Toxic Substances Control Requirements 10-2 C. StateWater Board Requirements 10-4 ii 10 Other State and Local Regulations (cont.) D. State Occupational Safety and Health Administration Requirements 10-4 E. California Trade and Commerce Agency Requirements 10-6 APPENDICES Appendix A - Air Resources Board's Final Regulation Order, Airborne Toxic Control Measure for Emissions of Perchloroethylene from Dry Cleaning Operations Appendix B - Air Resources Board's Final Regulation Order, Environmental Training Program for Perchloroethylene Dry Cleaning Operations Appendix C - Perchloroethylene Material Safety Data Sheet Appendix D - Sample Recordkeeping and Reporting Forms Appendix E - Department of Toxic Substances Control Fact Sheet on Contingency Plans Appendix F - Publicly Owned Treatment Works Arranged by Zip Code Appendix G - California Occupational Safety and Health Administration's General Industry Safety Orders - Article 67 Appendix H - California Trade and Commerce Agency's Office of Small Business Plant Registration and Assistance Programs Appendix I - Bibliography iii LIST OF TABLES Table Title Page 1-1 Dry Cleaning Solvent Characteristics 1-7 1-2 Technical Suitability of Alternative Dry Cleaning Solvents 1-7 3-1 Properties of Perchloroethylene 3-2 3-2 1991 Statewide Distribution of Machines and Perc Emissions by Machine Type 3-4 4-1 Exposure Limits for Perchloroethylene 4-4 4-2 Inhalation Response to Perchloroethylene 4-5 8-1 Probable Areas Where Leaks Can Occur 8-4 LIST OF FIGURES Figure Title Page 1-1 Solvent Usage by Type 1-5 3-1 Perc Usage by Industry 3-3 5-1 Back of a Closed-Loop Dry-to-Dry Machine 5-4 5-2 Diagram of a Still 5-10 5-3 Diagram of a Water Separator 5-11 6-1 Pounds of Clothes/Load 6-10 6-2 Completed Sample Pounds of Clothes/Load 6-11 6-3 Annual Report 6-14 6-4 Completed Sample Annual Report 6-15 7-1 Operations and Maintenance Checklist 7-13 7-2 Completed Sample Operations and Maintenance Checklist 7-14 8-1 Halogenated-hydrocarbon Leak Detectors 8-7 8-2 Checking for Leaks Around a Loading Door 8-8 8-3 Weekly Leak Inspection Checklist 8-10 8-4 Completed Sample Weekly Leak Inspection Checklist 8-11 8-5 Service and Repair Log 8-13 8-6 Completed Sample Service and Repair Log 8-15 iv INFORMATION FOR INSTRUCTORS PURPOSE The Environmental Training Program course was developed to provide dry cleaners with a good understanding of the benefits and requirements of the Airborne Toxic Control Measure for Emissions of Perchloroethylene from Dry Cleaning Operations (the Dry Cleaning ATCM). The Air Resources Board (ARB) staff developed this instructor manual to aid instructors in presenting a standardized curriculum to those attending the training course. The instructor manual will ensure that the information presented at Environmental Training Program course is consistent statewide. COURSE ORGANIZATION The curriculum for the Environmental Training Program consists of a reference manual and training slides. The reference manual will include instructional objectives, key points, summaries, discussion questions, and additional technical information. The manual is divided into ten chapters as follows: Chapter Subject 1 Introduction 2 Health Effects of Perchloroethylene 3 Perchloroethylene Usage and Emissions 4 Working with Perchloroethylene 5 Dry Cleaning Equipment and Operations 6 The ARB's Dry Cleaning ATCM 7 Operations And Maintenance Practices 8 Leaks and Leak Detection 9 Spills and Emergency Response 10 Other State and Local Regulations INSTRUCTOR PREPARATION Instructors shall have demonstrated a background in, and knowledge of, the following: operation and maintenance of dry cleaning systems, pollution prevention procedures, and environmental regulations pertaining to dry cleaning operations in California. The instructor must v also be able to effectively communicate this knowledge to dry cleaning personnel. This course is designed to minimize the time required to prepare for instruction. The instructor should identify the objectives of each chapter and then go over the contents of the chapter in class. When the review of the chapter is completed, the instructor should lead a discussion using the discussion questions provided in the reference manual. Upon completion of the training course, the ARB staff recommends that the instructor give a voluntary exam which will allow students to judge their knowledge of the information that has been presented. The instructor should focus on: posing the suggested questions for discussion; pointing out how the recommended practices can be applied in dry cleaning plants; and seeing that the key points for each chapter are covered in discussion and understood by all the students. Each instructor should read this manual and the student manual thoroughly before the course giving attention to the objectives and discussion questions for each chapter. Instructors are encouraged to make notes in the margins as reminders of instructional strategies, points to make, and examples to use. Instructors are also encouraged to have the following materials: A copy of the Dry Cleaning ATCM and Environmental Training Program Regulation A copy of this reference manual and slides for each student A copy of a voluntary exam based on the questions listed in this reference manual for each student Visual aids such as portable leak detectors, overheads, slide projectors, etc. STUDENT PREPARATION Students are expected to read the reference manual before attending the course. It is best to go over the chapters one at a time. The students will be given the objectives of the chapter, and will complete the discussion questions at the end of the chapter. The instructor will lead a discussion at the end of each chapter to ensure that students have the knowledge to answer the questions provided in the manual. vi CHAPTER 1 INTRODUCTION INSTRUCTIONAL OBJECTIVES Upon completion of this chapter, students will be able to: Understand the purpose of the Environmental Training Program; Have a background on the history of dry cleaning; and Identify the advantages and disadvantages of the solvents used in dry cleaning. KEY POINTS 1. The Air Resources Board has adopted two regulations that affect the dry cleaning industry.
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