BOARD MEETING DATE: December 3, 2004 AGENDA NO. 26

This report is presented to the Board as a fulfillment of staff’s commitment to report to the Board two years from the date of amendments to Rule 1421 (December 2002). At that time, staff stated a report to the Board would be made following an assessment of the availability of alternative technologies and their associated risks and a review of health risk information on the alternatives and perc.

Hydrocarbon-based, silicon-based, carbon dioxide (CO₂) and wet cleaning are the major alternative technologies commercially available and currently in use. There are over a dozen manufacturers of wet cleaning equipment, and over a dozen manufacturers represented in the hydrocarbon equipment the District has recently permitted. There are two manufacturers of CO₂ equipment represented in the region. The following table lists the estimated number of each of these technologies currently in operation in the Basin and the average capacity and cost of the basic equipment. The costs are approximately the same for solvent machines, as reported to the Stationary Source Committee in December 2003 and estimated in the staff report when the rule was adopted. The previous estimate for CO₂ machines of $80,000 - 90,000 was based on one machine and an older model. As the majority of wet cleaning machines are manufactured in Europe, the cost for wet cleaning, previously estimated to be between $27,000 - $37,000 for machines with capacity ranging from 35 to 50 lbs., is now higher due to monetary changes in the Euro. For comparison purposes, the new cost range for perc machines is $33,000 - $48,000, for similar capacity ranges.

Technology	Number of Installations Since Rule Amendment*	Average Capacity Size of Basic Equipment	Average Cost of Basic Equipment*
Hydrocarbon	235*	50 lbs	$54,000
Green Earth ™	44	60 lbs	$50,500
CO₂	2 mixed (with wet)	50 lbs	$123,000
Wet Cleaning	31	40 lbs	$45,000

*See Grant Program section – many facilities received grants from AQMD to offset some of the cost.

Recent, preliminary data from CARB indicated a statewide decrease of perc machines of about 16% when compared to a survey conducted about 11 years ago. During the same time period, the amount of clothes dry cleaned remained about the same. There was an increase of about the same amount of dry cleaning machines using alternative technologies.

Perc
A literature search found no new studies regarding the toxicity of perc but there were two literature reviews published.

A critical review of the epidemiological literature on occupational exposure to perchloroethylene and cancer appeared in the International Archives of Occupational and Environmental Health (2003 76:473-491 DOI 10.1007/s00420-003-0457-2) funded by the Halogenated Solvent Industry. That review examined forty-four papers that provided data from up to seventeen cancer sites were included. The investigators found "the current epidemiological evidence does not support a conclusion that occupational exposure to PCE is a risk factor for cancer of any specific site. Priority areas in which additional data are most needed include cancers of the esophagus and bladder." The review states "…one’s inability to find homogeneity among the results of the cancer-specific literature cannot be interpreted as lack of effect." The review also states "Scientific evidence was inadequate for laryngeal, kidney, esophageal, and bladder cancer. Nevertheless, because of a number of positive findings suggested from some of these epidemiological studies (e.g., for esophageal cancer), one cannot definitely rule out the possibility that associations between PCE and some cancers exist in humans."

A second literature review sponsored by U.S. EPA and summarized in the April 2004 paper Summary Report of the Peer Review Workshop on the Neurotoxicity of Tetrachloroethylene (Perchloroethylene) Discussion Paper, examined exposure to populations employed in the industry as well as those not occupationally exposed (residents and those working near sources). The question was posed to the review panel as to the validity of the hypothesis that perc is hazardous to the adult nervous system. The response was "the pattern of results provides convincing evidence that Perc is hazardous to the adult nervous system."

Additionally, an update to the U.S. Department of Health and Human Services, Public Health Service, National Toxicology Program Report on Carcinogens (Tenth Edition) was published in December 2002. The report concludes that perc is reasonably anticipated to be a human carcinogen.

Green Earth™
Dow Chemical is conducting a study on potential toxicity of Green Earth™, a silicon-based cleaning solvent, in laboratory rats. Preliminary data released after the adoption of Rule 1421 amendments showed increases in tumors for the highest dosage group after 2 years of exposure. Additional work by Dow is underway, but final results from this study are not expected for 1-2 years.

Other
Although there are currently no permit applications with the District for the compound 1-bromopropane, this is an emerging alternative technology for dry cleaning. The Cal/EPA, Office of Environmental Health Hazard Assessment (OEHHA) published a Notice of Intent to List a Chemical under Proposition 65 for 1-bromopropance on October 8, 2004. Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, requires the state to compile a list of substances known to cause cancer or reductive toxicity. OHEEA proposed to list 1-bromopropance as a reproductive toxin.

There is an ongoing project between Occidental College, Southern California Edison, Los Angeles Department of Water and Power, and Southern California Gas Company to monitor changes in facilities’ energy consumption when switching from perc to alternative technologies. To date, the study has preliminarily shown a saving in electrical and gas utilities for wet cleaning compared to other dry cleaning technologies. This study will continue and final numbers will be available late 2005. Southern California Edison has developed an "Early Retirement" incentive program for cleaners switching from perc to wet cleaning. This program assumes a life expectancy of 13 years for a perc machine and grants $528/year for replacing the perc machine with wet cleaning equipment before the end of the perc machine’s useful life. The City of Burbank has given a grant of 25% of the equipment cost for a wet cleaning installation replacing a perc operation because of its energy savings.

The AQMD’s Grant program is being successfully implemented. The total amount of funds authorized by the Board in 2002 for this program of financial assistance was $2 million. As of September 24, 2004, there have been 180 applications for financial assistance for hydrocarbon machines, 9 for Green Earth™ equipment (suspended April 2003), 41 for wet cleaning, and 2 for CO₂ equipment. The total number of grants given to dry cleaning operators is 157 with 75 under processing (installation, review, and/or final approval). Funds committed to Environmental Justice priority areas total $465,000 out of a total of $1.4 million committed. Funds committed include grants distributed and those pending approval and/or installation of equipment. Applications are still being accepted to utilize the remaining approximately $600,000.

One of the areas discussed extensively during rule development was the amount of perc emitted to the atmosphere from perc dry cleaning operations. At that time, no pre-existing sampling data was available, so staff performed two sampling test programs. The first sampling set tested 4 machines with primary control only; 2 with primary and secondary controls. The second sampling set tested 20 perc machines with primary and secondary control, and 11 hydrocarbon machines. The results showed an average 50% perc emitted and 34% VOC emitted from hydrocarbon machines.

To enhance the sample population, additional perc testing was done by staff after the rule amendment. The Technical Working Group for Rule 1421 met on June 4, 2003 to establish parameters for the sampling effort. It was agreed that facilities would be randomly selected from those with one perc machine equipped with primary and secondary controls resulting in a sample size of 25. Criteria for exclusion were agreed upon. Although the number of 20 samples has been proven to be statistically significant, the sample size was increased to accommodate any withdrawals from the program. It was agreed that the sampling period would be for 12 months with quarterly samples. It was established that the samples would come from waste drums which are kept separate from filters. The sampling effort was completed in September 2004. During the sampling period, five facilities were eliminated because of change of ownership or equipment replacement.

Data is being shared with the Technical Working Group for Rule 1421. The data is still being analyzed and the percentage of perc emitted has not yet been determined. Some of the facilities’ records were incomplete. To correct this problem, suppliers and waste haulers are being contacted in an attempt to get a better understanding of each facility’s operation over the year. In this on-going effort, AQMD staff will also examine the data for seasonal variation and compatibility with the 2002 sampling results. The results will be shared with the Working Group for their comments.

AB 998 (Lowenthal) – Non toxic Dry Cleaning Incentive Program, approved in 2003, required CARB to place a $3/gal fee on manufacturers or distributors of perc in the state beginning January 2005, with an increase of $1/year until 2013. AB 998 provided for $10,000 grants for non-toxic, non-smog forming alternatives such as CO₂ and wet cleaning. AQMD staff is working with CARB staff as they develop criteria and set-up implementation of their grant program next year. AQMD staff will continue to coordinate with CARB on this program.

Edison’s Customer Technology Application Center demonstration center, showcasing alternative cleaning technologies, has been opened for about one year.

Since the rule was amended, the number of non-perc alternatives has significantly increased. The AQMD’s Grant Program is being successfully implemented. No new studies on the toxicity of perc or its alternatives have been initiated in that time. Two literature reviews have been cited and there is ongoing work by Dow Chemical regarding the potential toxicity of Green Earth™. The one-year sampling program has been completed and data analysis is ongoing to enhance the emissions information for perc dry cleaners. Staff will continue to work with the Working Group in completing the data analysis. The findings will be presented to the Stationary Source Committee after stakeholder review.