Proposal:

Amend Rule 1421 - Control of Perchloroethylene Emissions from Dry Cleaning Systems

Synopsis:

Proposed amendments have been developed to replace current Rule 1421 provisions with the state Airborne Toxic Control Measure (ATCM) Title 17 CCR, Section 93109, except the existing Rule 1421 secondary control requirements will be retained. The amendments propose to eliminate requirements not contained within the state ATCM and that have an insignificant impact on airborne emissions from perchloroethylene dry cleaning equipment. Additionally, reporting and recordkeeping requirements are streamlined.

Committee:

Stationary Source, April 18, 1997, reviewed.

Recommended Action:

1. Certify the Final Environmental Assessment for Proposed Amended Rule 1421 - Control of Perchloroethylene Emissions from Dry Cleaning Systems; and

2. Amend Rule 1421 - Control of Perchloroethylene Emissions from Dry Cleaning System, as proposed, in accordance with the attached Resolution.

James M. Lents, Ph.D.
Executive Officer

Overview

Proposed Amended Rule 1421 is being developed to replace the current Rule 1421 requirements to make them consistent with the state Airborne Toxic Control Measure (ATCM) requirements. These proposed amendments are supported by the business community as evidenced by comments received, including from the Korean Dry Cleaning Association and the Greater Los Angeles Dry Cleaning Association.

Background

On June 6, 1980, the AQMD adopted Rule 1102.1 - Perchloroethylene Dry Cleaning Systems to control the emission of perchloroethylene (perc), as a VOC, from dry cleaning operations.

In 1983 the California Legislature adopted Assembly Bill 1807. This bill mandated a program to identify and control toxic air contaminants. The program required the Office of Environmental Health Hazard Assessment (OEHHA) to evaluate the health risks of perc and other substances. In the evaluation process, OEHHA identified perc as a toxic compound.

In October 1991 the ARB accepted the findings of OEHHA and the ARB listed perc as a Toxic Air Contaminant (TAC). At about the same time, the EPA listed perc as a Hazardous Air Pollutant (HAP).

On October 12, 1993, the ARB adopted the ATCM for Emissions of Perchloroethylene from Dry Cleaning Operations establishing equipment, operating, and other requirements for California’s perc dry cleaners. The ATCM was then approved by the Office of Administrative Law on June 4, 1994. The ATCM allowed local districts to either adopt their own regulation or begin implementation of the ATCM. At that time the EPA had not approved the ATCM, so the AQMD proceeded with the development of proposed Rule 1421 which would be acceptable to both the state and the EPA.

On December 9, 1994, the AQMD adopted Rule 1421 to incorporate and implement the federal National Emission Standards for Hazardous Air Pollutants (NESHAP) and the state ATCM for perc dry cleaning facilities. Rule 1421, which in some respects has more stringent equipment and operating requirements than the ATCM, requires perc dry cleaning facilities to:

• phase-out transfer, vented, and self-service machines;
• use closed-loop, dry-to-dry machines;
• install primary, secondary, and fugitive control systems as appropriate;
• install waste water separators to control waste water emissions; and
• institute good operating, reporting, and recordkeeping practices.

The EPA granted approval to the ARB to implement and enforce the ATCM for perc on May 21, 1996. On June 27, 1996, following EPA approval of the ATCM, the proposed replacement of Rule 1421 with the ATCM was presented and discussed at the Home Rule Advisory Group meeting. At the meeting, the proposal was supported by the members of the Advisory Group.

Proposal

The proposed amendments are designed to make Rule 1421 consistent with the ATCM and at the same time not significantly impact emissions. Proposed amendments address equipment, training, recordkeeping, and reporting requirements.

Proposed amendments include the elimination of the fugitive control system requirement. Staff field evaluations and calculations revealed that the fugitive control system was demonstrated to achieve little or no emission reduction.

Proposed amendments include the elimination of the Waste Water Separator requirement. Staff conducted field studies to evaluate perc emissions associated with the waste water separator’s functions. Perc concentration in the waste water was determined from these field studies using AQMD laboratory analysis. Staff has estimated that perc emissions from waste water at even larger dry cleaners are, at most, only a few grams per day. In conclusion, staff has determined that the waste water separator requirement represents an added cost for a negligible emission reduction.

Proposed amendments include streamlining the recordkeeping, reporting, and training requirements.

In conclusion, there are no significant emission reductions or emission increases expected as a result of the proposed amendments. The proposed amendments will streamline the rule and make it more consistent with the state requirements. The continued phase-in of new and replacement equipment, coupled with the requirement for primary and secondary control systems, will ensure that the proposed amendment is consistent with the emission reductions and health benefits in existing Rule 1421.

AQMP and Legal Mandates

Based on staff’s analysis of the proposed amendments, no significant emission impacts are projected. Since Rule 1421’s adoption in 1994, staff has found that some of the control technologies required and several administrative requirements were burdensome to industry while not providing emission reductions necessary to validate their inclusion in the rule.

Environmental Assessment

Pursuant to CEQA, the proposed amendments to Rule 1421 are a "project" and, as such, a Draft Environmental Assessment (EA) has been prepared. The Draft EA did not identify any significant environmental impacts and was circulated for a 30-day public review and comment period which ended April 14, 1997. No comments were received on the Draft EA such that it is now a Final EA.

Overall emissions will not change as a result of the proposed amendments. No significant additional compliance costs are expected, and no adverse socioeconomic impacts are anticipated as a result of the proposed amendments.

Implementation Plan

No implementation plan is expected since the proposed amendments to Rule 1421 are intended to make the current rule more consistent with the federally-approved ATCM.

Resource Impacts

Not applicable.

Attachments

A. Summary of Proposed Amendments
B. Rule Development Process
C. Key Contacts
D. Resolution
E. Proposed Rule Language
F. Final Staff Report
G. Final Socioeconomic Assessment
H. CEQA Analysis

ATTACHMENT A

SUMMARY OF PROPOSED AMENDMENTS

Rule 1421 - Control of Perchloroethylene Emissions from Dry Cleaning Systems

· Replace current Rule 1421 requirements to make them consistent with ATCM requirements.

· Eliminate the fugitive control system requirement.

· Eliminate the waste water separator requirement.

· Extend the leak-repair duration from 15 to 30 days.

· Eliminate some of the daily and monthly recordkeeping consistent with the ATCM. This information will be maintained on an annual basis.

· Eliminate the training requirement, except for one trained operator per facility.

· Include provision directly referencing the NESHAP for major sources.

· Modify or delete some definitions to incorporate NESHAP and ATCM requirements.

· Replace EPA Test Method 18 with ARB Method 422 or NIOSH Method 1003.