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Cal Air Board trumps EPA
with new rules for perc rules |
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California state air pollution officials are proposing new regulations for that
state
’s perc drycleaners that go beyond the new federal air pollution rules that EPA
is considering.
The proposal by the Air Resources Board staff, which was presented to the board’s governing body last month, would hasten the replacement of older perc
drycleaning machines while encouraging, and in some cases requiring, the use of
non-perc alternatives.
Like the EPA proposal, the California plan addresses “co-residential” perc plants — those that share a wall, floor or ceiling with a residence. California
regulators want to prohibit new perc plants in co-residential situations and
are calling for the phase-out of perc in existing co-residential facilities by
2010.
A perc phase-out in co-residential facilities is one of two options being
considered by EPA, the other being a requirement that perc machines in such
facilities be enclosed in a vapor barrier room. The vapor barrier option for
co-residential facilities was not offered in the California proposal.
California would also add a new category that would call for special regulation
of perc plants: those that are located near a
“sensitive receptor.”
A sensitive receptor could be a school, residence, childcare center, hospital or
other health-care facility or foster care home.
New perc plants would have to be located at least 300 feet from a sensitive
receptor. They would also have to be at least 300 feet from the boundary of an
area zoned for residential use. All new perc plants, regardless of location,
would have to use closed loop machines with integral secondary emission
controls.
Existing perc plants within 100 feet of a sensitive receptor would be required
to install an integral secondary control machine or a non-perc alternative by
July, 2009 or when the existing machine is 10 years old, whichever is later.
All other existing perc plants would have until July 2010 to install an integral
secondary control machine or non-perc alternative. A current machine could
continue in use until it is 15 years old if it is not that old by the 2010
deadline.
All current perc plants would also have to install “enhanced ventilation.” The deadline for that depends on the proximity of a sensitive receptor: if one
is within 100 feet, the ventilation would have to be installed by July, 2009;
if more than 100 feet, the deadline is July, 2010.
Enhanced ventilation is defined as a system designed to capture fugitive
emissions from the drycleaning machine
— local ventilation systems or partial or full vapor barrier rooms.
New wastewater treatment rules are also included in the California proposal.
Wastewater would either have to be hauled by a registered hazardous waste
transporter or handled in an in-plant perc wastewater treatment unit that meets
state requirements.
Another new requirement will be annual inspections of the drycleaning machine’s drum. This involves installing a sampling port for reading perc concentrations
which would
have to be under 500 parts per million (ppm) upstream of the carbon bed and less
than 1,000 ppm at the end of the drying cycle during normal operation and after
the initial startup. The concentration downstream of the carbon bed would have
to be less than 100 ppm while the secondary control is operating.
The Air Resources Board staff estimates compliance costs for cleaners could
range from zero if the plant is already in compliance to $23,000 for the
incremental cost of a secondary control machine. But even those plants that
already have machines that meet the requirements would likely face an extra
annual cost to arrange for the drum concentration checks.
The ARB staff also acknowledged that the cost of the new rules could be more
than some cleaners can withstand.
“Some marginal drycleaning business may not have the capital necessary to comply
with the amendments, which may result in closure,
” the ARB report said. However, the phase-out periods should minimize the
financial impact by maximizing the remaining useful life of non-complying
drycleaning machines, the report said.
As with the federal EPA proposal, some environmental groups are urging
California to go further than proposed in restricting the use of perc. Some
would like to see the state follow the example of the South Coast Air Quality
Management District by phasing out perc completely by 2020
— or sooner.
ARB said that option was considered but it is concerned that its adoption would
result in
”significant increases in hydrocarbon emissions” as well as increase the compliance cost of the regulation as cleaners replace
perc machines with hydrocarbon units.
If the state went even further and eliminated both perc and hydrocarbon emitting
machines
— basically limiting cleaners’ choices to water-based methods or liquid carbon dioxide — the compliance cost would be seven times greater than the proposed rule and
have the effect of increasing the average cost to clean a garment by $1.40.
The governing board was scheduled to hold a hearing on the proposal on May 25.
The board can either approve the proposal as presented or take it under
advisement for further review and modification.
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