BOARD MEETING DATE: February 18, 2000 AGENDA NO. 26
PROPOSAL:
Approve the Monitoring, Recordkeeping, and Reporting Task Force Recommendations to Streamline Recordkeeping for Dry Cleaning Operations
SYNOPSIS:
The Monitoring, Recordkeeping, and Reporting (MRR) Task Force has developed a consensus proposal to streamline recordkeeping for dry cleaning operations within AQMD. This proposal will reduce or eliminate unnecessary recordkeeping while maintaining rule enforceability. It is recommended that the Board direct staff to implement this proposal as detailed in the Board letter.
COMMITTEE:
Not Applicable
RECOMMENDED ACTION:
Approve the Monitoring, Recordkeeping, and Reporting Task Force Recommendations to streamline VOC Recordkeeping for dry cleaning operations as contained in the Board letter.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
At the suggestion of Chairman Burke, the AQMD Governing Board established the Monitoring, Recordkeeping, and Reporting Task Force (Task Force) in April 1999 to develop specific recommendations on how to streamline the MRR requirements for facilities subject to Regulation XI – Source Specific Rules, Regulation XX – RECLAIM, and Regulation XXX – Title V, while maintaining the air quality objectives and business needs of AQMD’s customers. AQMD Vice-Chair Norma Glover was designated as the Task Force Chair and Board member Ron Loveridge was appointed to the Task Force, to provide guidance and direction to the Task Force activities. The Task Force includes representatives from industry, state and federal government, and businesses that are directly or indirectly impacted by the AQMD MRR requirements. (Attachment A provides a complete list of Task Force members’ names and affiliations.)
The AQMD Governing Board approved the first Task Force Progress Report, with
specific recommendations to streamline VOC recordkeeping, on January 21, 2000.
In the course of developing the proposal for VOC sources, the Task Force had
also explored streamlining MRR requirements for Perchloroethylene (Perc)1
dry cleaning operations. After an initial review of these requirements, the Task
Force recommended that AQMD staff meet with Perc dry cleaners to understand
their concerns about recordkeeping for Perc. Based on meetings with the
California Cleaners, Korean Dry Cleaners & Laundry, and Greater Los Angeles
Dry Cleaners Associations, a simplified Perc recordkeeping form was developed to
reduce the burden to affected businesses, while maintaining the enforceability
of applicable rules and permits. This form will be translated into Korean and
Spanish language, and is expected to help both the affected sources and the AQMD
staff in compliance determination in the most efficient manner. (A copy of the
proposed form is shown in Attachment B).
Proposal
The MRR requirements for Perc dry cleaning operations are contained in (1)
AQMD Rule 1421 – Control of Perchloroethylene Emissions from Dry Cleaning
Systems, (2) the federal National Emission Standard for Hazardous Air Pollutants
(NESHAP)2 and (3) the state Airborne Toxics
Control Measure (ATCM)3. AQMD Rule 1421
implements both the NESHAP and the state ATCM, and requires the following
records to be kept:
- Daily pounds of materials cleaned per day;
- Purchase and delivery receipts for Perc;
- Date(s) and gallons of Perc added directly by facilities to solvent tank of each dry
cleaning machine;
- Completed Leak Inspection Checklist and the Operation and Maintenance
Checklists; and
- An annual report showing the: Record of completion for each trained operator; Total pound of materials cleaned per load and the gallons of Perc used for all
solvent additions in the reporting period; and Average facility mileage from all solvent additions in the reporting period.
1 Perc is not a Volatile Organic
Compound (VOC) and is regulated under AQMD Regulation XIV to control its
emissions from dry cleaning operations. 2 NESHAP for Source Categories: Perchloroethylene Dry Cleaning
Facilities (40 Code of Federal Regulations [CFR] 63.320, et seq). 3 ATCM for Emissions of Perchloroethylene from Dry Cleaning
Operations (17 California Code of regulations [CCR] 93109, et seq).
The Task Force is aware that any proposed changes in Perc recordkeeping requirements or AQMD policy governing Perc dry cleaning operations must ensure continued compliance with the state ATCM and the federal NESHAP requirements. Furthermore, the Task Force recognizes that the California Air Pollution Control Officers Association (CAPCOA) will soon submit a proposal to CARB to revise the ATCM requirements dealing with the leak inspection and the Operation and Maintenance Checklists. In keeping with this goal, the proposed form:
- Records, in one form rather than three currently separate forms, the daily pounds of
materials cleaned per load, the monthly and annual Perc usage, and average facility
annual mileage. As required by Rule 1421, Dry Cleaners must keep the purchase
and delivery receipts as underlying supporting evidence for the total monthly
or annual Perc usage;
- May be used as the annual report, when attached with copies of certificates for all
trained operators; and
- May be substituted with an alternative format for maintaining all the data required in
the proposed form.
The format of the proposed form for streamlined Perc recordkeeping is designed to incorporate the data necessary to ensure compliance with applicable AQMD, state, and federal rules or permit conditions in an easy but enforceable manner. An alternative format is considered equivalent if it incorporates all required data contained in the proposed form.
The proposed streamlined Perc recordkeeping form does not need an adoption or amendment of any AQMD rule or regulation. However, upon conclusion of the CAPCOA’s effort to revise the leak inspection, and the Operation and Maintenance Checklists, the Task Force recommends that this matter be further reviewed for additional simplification.
Public Process
The AQMD staff met with six members of different dry cleaning associations in order to prepare a draft recordkeeping form for Perc dry cleaning operations. On November 6, 1999, staff presented the draft form in a public workshop to seek public review and comments.
Task Force Recommendations
It is recommended that the Board approve this proposal to streamline Perc Recordkeeping for dry cleaning operations and direct staff to:
Begin accepting the suggested Perc recordkeeping form for recording the daily pounds of materials cleaned per load, the monthly and annual Perc usage, and average facility annual mileage;
Allow the proposed form, with attached copy of certificate for all trained operators, to be used as the annual report; and
Allow the use of an alternative format for maintaining all the data required in the applicable AQMD, state, and federal rules, and permits.
Resource Impact
Existing AQMD resources are sufficient to implement the proposed streamlined Perc recordkeeping system with no impact on the budget.
Attachment A: List of Task Force Members
Attachment B: Proposed Perc Recordkeeping Form for Dry Cleaning Operations
ATTACHMENT A
MONITORING, RECORDKEEPING AND REPORTING TASK FORCE MEMBER LIST
AQMD Governing Board
(Chair) Norma Glover, AQMD Governing Board Vice-Chair
Ronald Loveridge, AQMD Governing Board Member
State and Federal Regulatory Agency
Andrew Steckel, U.S. Environmental Protection Agency
Stephanie Trenck, California Air Resources Board
Other Members
Greg Adams, Sanitation Districts of Los Angeles County
Dale Botts, Steelcase/Orange County Business Council
Curt Coleman, California Manufacturers Association
Douglas F. Henderson, Western States Petroleum Association
Gene Lopez, California Auto Body Collision Association
Jackie Smith, California Cleaners Association
Jeb Stuart, Construction Industry Air Quality Coalition
Beverly Ziegler, Ziegler Associates
AQMD Staff Liaison
Dr. Barry Wallerstein, Executive Officer
Dr. Anupom Ganguli, Planning & Rules Manager
Peter Mieras, District Prosecutor
Monitoring, Recordkeeping, & Reporting Team
Adewale Oshinuga, Air Quality Engineer II
Emmanuel Quizon, Air Quality Engineer I
Marian Coleman, Air Quality Inspector III
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This page updated:
June 29, 2010
URL: http://www.aqmd.gov/hb/2000/000226a.html
Record of completion for each trained operator;