BOARD MEETING DATE: May 2, 2003
AGENDA NO. 22
Implementation Status Report on Rule 1102 – Dry Cleaners Using Solvent Other than Perchloroethylene
SYNOPSIS:
When Rule 1102 was amended in November of 2000, the Board directed staff to prepare an implementation status report to assess the availability, cost-effectiveness and feasibility of closed-loop machines and other appropriate technologies for replacing transfer machines that clean reusable soiled textile materials pursuant to the requirements of California Health and Safety Code §25144.6(b). This report meets this directive by summarizing compliance efforts by operators at the affected facility.
COMMITTEE:
Stationary Source, April 25, 2003, Reviewed
RECOMMENDED ACTION:
Receive and file.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Rule 1102 contains both equipment and operating requirements for dry cleaning operations that use solvent other than perchloroethylene1. Rule 1102 was originally adopted on January 6, 1978, and amended five times, with the most recent amendment occurring on November 17, 2000. As amended, Rule 1102 required the phase-out of most transfer machines by January 1, 2003, but allowed a delayed compliance date of January 1, 2005, for one unique large industrial facility that relies on transfer machines to clean reusable soiled textile materials in accordance with California Health and Safety Code (HSC) §25144.6 (b). All dry cleaning facilities subject to the January 1, 2003 compliance date are no longer using their transfer machines.
1Rule 1102 does not apply to dry cleaning operations using perchloroethylene as a cleaning solvent. These operations are regulated by Rule 1421 - Control of Perchloroethylene
From Dry Cleaning Systems.
The remaining facility subject to the January 1, 2005 compliance date, M.L. Winters Industrial Cleaning (Winters) located in Pico Rivera, is substantially different from the neighborhood commercial dry cleaner because it cleans industrial gloves and absorbents with Stoddard solvent to recover and recycle oils that would otherwise be disposed of as hazardous waste if the gloves and absorbents were thrown away. The delayed compliance date was included because closed-loop technology for use with Stoddard solvent had not yet been developed for this type and size of industrial application. According to the November 2000 staff report for proposed amended Rule 1102 (Appendix C), the permitted VOC emissions at the Winters’ facility were estimated at 55,440 pounds per year. Further, the staff report assumed that replacing the transfer machines with closed-loop equipment would reduce VOC emissions by approximately 30 percent.
As part of the November 2000 amendments, the Governing Board directed staff to prepare an implementation status report to assess the availability, cost-effectiveness and feasibility of closed-loop machines and other appropriate technologies for replacing the transfer machines at Winters in time to meet the January 1, 2005 compliance date. This report meets this directive by summarizing compliance efforts at the affected facility.
Status of Compliance Efforts
As part of its efforts to find equipment that meets Winters’ cleaning needs and complies with Rule 1102, Winters has collaborated with two manufacturers regarding the design and availability of a large-capacity closed-loop machine. The first manufacturer, Wientjen (located in the Netherlands), manufactures a large-capacity machine (i.e., 220 pounds per load) and proposes to retrofit this machine so it will function with Winters’ existing Stoddard solvent recovery system. The other manufacturer, Columbia, also has designed a prototype machine that uses DF-2000 solvent and can wash approximately 160 pounds per load. Though larger than most commercially available machines on the market, the capacity of each of these machines is not large enough to handle the same volume of materials on a daily basis, unless Winters extends its operating hours and operates multiple machines. Though the performance of these machines has not been tested in practice, initial tests suggest that they have potential to satisfy Winters’ design needs and comply with Rule 1102. However, if the size and the performance of the closed-loop machines can meet Winters’ performance needs, preliminary capital and operating cost data suggest that compliance with Rule 1102 may be very expensive. In addition to performance, further analysis on compliance costs and impacts on the facility is warranted.
Conclusion and Recommendation
The current status of the new prototype machines suggests that closed-loop technology for Winters’ industrial applications may be available by January 1, 2005. The timing of compliance and the feasibility of the prototype machines is dependent upon a number of factors, including but not limited to when the equipment can be permitted, installed and tested. There are a number of factors (as summarized in the Attachment) that may impede the facility’s progress in installing compliant equipment by the final compliance date. The attachment also contains information on the prototype equipment and annual operating and maintenance costs. Therefore, staff recommends that a status report be prepared by January 2004 to provide the Board with information on the status of the new equipment and Winters’ compliance efforts with respect to meeting the January 1, 2005 compliance date contained in Rule 1102. Further, based on the preliminary information on the equipment costs provided for prototype equipment, staff recommends that the preparation of a cost-effectiveness analysis be deferred to the January 2004 status report.
Rule 1102 Implementation Status Report
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