Fact Sheet

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM PERCHLOROETHYLENE DRY CLEANING FACILITIES--FINAL RULE

[Editor's note: EPA provided the HAP Subcommittee with a fact sheet in October 1993 which was scanned into electronic format. The editor has corrected some errors in EPA's fact sheet and significantly reformatted the tables. The fact sheet has also been revised to reflect amendments to the rule.]

BACKGROUND

Dry cleaners are a major source of perchloroethylene (also referred to as PCE, PERC, tetrachloroethene, and tetrachloroethylene) , one of the toxic air pollutants Congress has required the Environmental Protection Agency (EPA) to regulate under the Clean Air Act of 1990. PCE is known to cause cancer in animals and is suspected to cause cancer in humans. PCE also has non-cancer toxic effects that make it desirable to minimize PCE emissions.
Under Section 112 of the Clean Air Act, the EPA proposed on December 9, 1991, national emission standards for hazardous air pollutants (NESHAP) to limit PCE emissions from both new (constructed on or after December 9, 1991) and existing (constructed before December 9, 1991) dry cleaning facilities.
In response to public comments received on the proposal, a notice of availability of new information on control of PCE emissions during clothing transfer was published on October 1, 1992. Additional comments were received.
The final rule was published on September 22, 1993, in the Federal Register, volume 58, starting on page 49356.

REQUIREMENTS OF THE EPA DRY CLEANER RULE

The rule breaks dry cleaners into three separate categories--small "area" sources, large "area" sources, and "major" sources--and contains different requirements for each category. (See Table 1.)
There are two types of dry cleaning machine systems: dry-to-dry and transfer. A dry-to-dry machine consists of one machine, which does both the washing and the drying of the articles being cleaned. A transfer machine consists of two machines: a washer and a dryer. Transfer of clothing between a washer and a dryer is considered to be a significant source of emissions.

TABLE 1. REQUIREMENTS OF THE PCE DRY CLEANING NESHAP
Requirement	Small Area Source	Large Area Source	Major Source
Applicability
Facilities with:	Facility-wide PCE Consumption (gallons PCE/year)
Only Dry-to-Dry	< 140	140-2,100	> 2,100
Only Transfer	< 200	200-1,800	> 1,800
Dry-to-Dry & Transfer	< 140	140-1,800	> 1,800
Process Vent Controls
Existing Systems	None	Refrigerated condenser (or equivalent) Carbon adsorbers installed on existing machines before 9/22/93 can remain
New Systems	Refrigerated condenser (or equivalent)		Refrigerated condenser and small carbon adsorber (or equiv.)
Fugitive Controls
Existing Systems	- Leak detection/repair - Store all PCE solvent & waste in sealed containers		Area source requirements plus: Transfer machine systems are contained inside a room enclosure
New Systems	Area source requirements plus: No new transfer machine systems allowed
Operation & Maintenance
All Systems	Operate and maintain dry cleaning systems according to manufacturer's specifications and recommendations.
Monitoring
Existing Systems	Same as large area source	Refrigerated condenser (RC): Measure the RC outlet temperature at the end of the cycle on a dry-to-dry machine or dryer. (Must be less than or equal to 45ºF.) Measure the RC inlet and outlet temperature difference on a washer. (Must be greater than or equal to 20ºF.) Carbon adsorber (CA): Measure the PCE concentration out of the CA with a colorimetric detector tube. (Must be less than or equal to 100 ppm.)
New Systems	None
Recordkeeping
All Systems	Each facility must maintain records of PCE purchases and the calculation of yearly PCE consumption each month, along with dated records of all monitoring and leak detection and repair activities. The last five years of records must be kept.
Reporting & Compliance
Existing Systems	Each facility must submit an initial report by 06/18/94 and compliance report by 06/18/94. Reports must be certified by a responsible official. Each facility also has until 12/20/93 to comply with pollution prevention and record-keeping requirements. Large Area and Major facilities must comply with process controls by 9/23/96 and must submit an additional compliance report by 10/22/96.
New Systems	All other new facilities must comply upon start-up with all requirements and submit a compliance report within 30 days from the date the dry cleaner must be in compliance or on 06/18/94, whichever is later. However, there are special compliance and notification requirements for dry cleaning systems that were constructed during 12/9/91 land 9/21/93.

The EPA's final rule requires all new dry cleaning machines to be dry-to-dry machines. It does not, however, require the replacement of existing transfer machines with new dry-to-dry machines.

There are two sources of PCE emissions at dry cleaning facilities: process vent emissions (that is, the dry cleaning machine vent); and fugitive emissions (for example, clothing transfer, equipment leaks, and solvent exposed to air, and so forth). Process vent emissions are controlled through the use of refrigerated condensers or carbon adsorbers. Fugitive emissions from clothing transfer at transfer machines are controlled through room enclosures. Other fugitive emissions are controlled through leak detection and repair, keeping PCE and PCE wastes in sealed containers, keeping machine doors shut, and proper operation and maintenance of equipment .

The EPA's rule requires control of process vent emissions at all new dry cleaning facilities. It also requires control of process vent emissions at existing large area source and major source dry cleaning facilities.

The rule requires control of fugitive emissions at all new dry cleaning facilities. It also requires control of fugitive emissions at all existing dry cleaning facilities. However, only transfer machines at major source dry cleaning facilities are required to control fugitive emissions by installing a room enclosure.

The rule requires the use of refrigerated condensers to control process vent emissions at new dry cleaning facilities. It also requires the use of refrigerated condensers to control process vent emissions at existing dry cleaning facilities, except those existing facilities that have already installed a carbon adsorber for control of process vent emissions prior to 9/22/93. These facilities may continue to use this carbon adsorber to comply with the requirements of the rule.

All existing dry cleaners must submit an initial notification report by 06/18/94, to the EPA Region for each of their locations. The notification reporting requirements are in the rule. Forms supplied by EPA may be used to fulfill this notification requirement. Dry cleaning systems that were constructed between 12/9/91, and 9/21/93, can either meet the requirements for new facilities or comply with the special rule of Section 112 (i) (2) of the Clean Air Act. For assistance with complying with the special rule, refer to the EPA forms or contact EPA.

Each existing facility must comply with all requirements of the rule except for the refrigerated condenser by 12/20/93. Existing large area source and major source dry cleaning facilities must comply with installing a refrigerated condenser and also, for any major source transfer machines, a room enclosure, by 9/23/96. All new dry cleaning facilities must comply with the rule when they begin operation. However, dry cleaning systems that were constructed between 12/9/91, and 9/21/93, can either comply with the requirements for new facilities or comply with the special rule of Section 112 (i) (2) of the Clean Air Act. For assistance with complying with the special rule, refer to the EPA forms or contact EPA.

Each existing facility must submit a compliance report to EPA certifying that the facility is in compliance with all the requirements of the rule except for the refrigerated condenser installation requirement by 06/18/94. Existing large area source and major source dry cleaning facilities must submit an additional compliance report to EPA certifying that the facility is in compliance with the control requirements for a refrigerated condenser and also, for any major source transfer machines, a room enclosure, by 10/22/96. All new dry cleaners must submit a compliance report within 30 days from the date the dry cleaner constructs the new facility or installed the new dry cleaning machine or dry cleaning system or by 06/18/94, whichever is later.

IMPACTS

Nationwide Impacts

Note: Impacts are estimates given for 1996. 1996 is the year that all facilities must comply with the rule, and will be the first year that the rule is expected to have its maximum impact.
In 1996 about 25,000 commercial and industrial dry cleaning facilities will be in operation. Although the dry cleaning industry's growth is currently stable, about 7,700 of these 25,000 facilities will be new facilities built to replace existing facilities that retire. Of these 7,700 new facilities, about 400 are estimated to be uncontrolled in the absence of the rule and, as a result of the rule, will be required to install process vent control. In addition, the EPA rule will require about 3,200 existing uncontrolled facilities to install controls on process vents.
The rule will result in a total maximum national PCE emissions reduction of 6,600 megagrams (Mg) (7,300 tons) from projected 1996 emission levels.
Energy: Total maximum national increase in electricity use (needed to operate the control devices) of 280,000 kilowatt hours per year (kwh/yr) in 1996 for new facilities and 2.5 million kwh/yr for existing facilities.
Annualized Cost: Total national increase of $0.5 million per year for new dry cleaning facilities and $3.4 million per year for existing facilities in 1996.
Capital Cost: Total national increase of $3 million for new dry cleaning facilities and $32 million for existing dry cleaning facilities in 1996.

Typical facility impacts for an existing, uncontrolled, 35-pound dry-to-dry machine located at an area source:

Perchloroethylene Emission Reductions: Individual reduction of 0.82 megagrams per year (0.91 tons per year) from projected 1996 emission levels.
Wastewater: Total maximum increase of 0.03 kilograms per year (0.07 pounds per year) of PCE in wastewater in 1996.
Solid Waste: No increase for the typical facility.
Noise: No incremental impacts.
Energy: The increase in electricity use (needed to operate refrigerated condenser) of 604 kilowatt hours (kwh) per year in 1996.
Annualized Cost: Increase of $1,100 per year in 1996. This includes the annualized cost of purchasing a refrigerated condenser and the annual operation and maintenance costs associated with the refrigerated condenser.
Capital Cost: Increase of $6,300 year in 1996. This is the average cost of a refrigerated condenser.

Please Note: This fact sheet is not a substitute for reading and understanding the EPA PCE dry cleaning rule.

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