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Cal Air Board trumps EPA
with new rules for perc rules
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.