Proposal:

Set Public Hearing June 13, 1997 to 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 unnecessary 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:

Set Public Hearing June 13, 1997 to amend Rule 1421 - Control of Perchloroethylene Emissions from Dry Cleaning Systems.

James M. Lents, Ph.D.
Executive Officer

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 Compound (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 May 4, 1994. The EPA granted approval to the ARB to implement and enforce the ATCM for perc on May 21, 1996.

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;
• fuse 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.

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 Working Group meeting. At the meeting, the proposal was supported by the members of the working group and staff was told to begin the rule development process.

Proposal

Proposed Amended Rule 1421 replaces 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.

The proposed amendments are designed to make Rule 1421 more consistent with the ATCM and at the same time not significantly impact emissions; they 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 be ineffective and achieves little or no emission reduction. Further, the goal of the proposed amendments to Rule 1421 is to eliminate ineffective controls that are not in the ATCM.

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. Consistent with the ATCM, staff proposes eliminating unnecessary recordkeeping and allowing each facility to have only one trained operator.

In conclusion, there are no significant emission reductions or emission increases expected as a result of the proposed amendments. The proposed amendments are intended to 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 human 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 Supplemental Environmental Assessment (SEA) has been prepared. The Draft SEA does not identify any significant environmental impacts and was circulated for a 30-day public review and comment period which ended April 18, 1997. All comments received will be addressed and incorporated into the final SEA for the proposed project.

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

Summary of Proposed Amendments
Rule Development Process
Key Contacts
Proposed Rule Language
Draft Staff Report
Draft Socioeconomic Assessment
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.

· Elimination of the fugitive control system requirement.

· Elimination of the waste water separator requirement.

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

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

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

· Provision directly referencing the NESHAP for major sources.

· Modification or deletion of some definitions to incorporate NESHAP and ATCM requirements.

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