EPA clarifies clean-air rules for IFI
Third-generation machines, monitoring issues resolved
Clarifications on several points of the clean-air rules for perc drycleaners
adopted last year by EPA have been provided to the International Fabricare
Institute and the Halogenated Solvents Industry Alliance.
IFI and HSIA met in February with EPA officials to discuss what IFI
characterized as
“lingering ambiguities” in the rules that led to different interpretations of what was required of
drycleaners.
The clarifications relate to requirements for monitoring perc concentrations in
the drycleaning machine drum, recording the temperature of the refrigerated
condenser and use of third-generation cleaning machines.
On the latter point, IFI said that EPA has advised that third-generation
equipment that was in use prior to Dec. 21, 2005 can be moved from one location
to another and no secondary carbon adsorption upgrade is required.
A third-generation machine that was installed before Dec. 21, 2005, can continue
in use for the life of the equipment or until repairs constitute 50 percent of
the cost of the original machine, IFI said.
If the total cost of repairs, including parts, exceeds 50 percent of the
original cost of the equipment, the cleaner would need to purchase a new
fourth-generation machine or another third-generation machine that had been
installed before Dec. 21, 2005.
A third-generation machine that was installed after Dec. 21, 2005, must be
refitted with secondary carbon absorption immediately, according to information
EPA provided IFI and HSIA. Adding carbon adsorption has the effect of
transforming a third-generation machine into a fourth-generation machine.
“In essence,” IFI said, “except for the exception previously detailed, after Dec. 21, 2005, only
fourth-generation PCE equipment should be installed.
”
On the issues of measuring perc concentration in the drum and measuring
refrigerated condenser temperature, IFI noted that neither is required for most
drycleaners.
Only those cleaners classified as “major sources” using more the 2,000 gallons of perc a year must measure drum concentrations.
And for most cleaners, the temperature measurement requirement has been
replaced by a new one that calls for recording the pressure gauge on the
refrigeration system.
“You should only be reading and recording temperature if your equipment does not
have pressure gauges,
” IFI said.
IFI pointed out that not being required to purchase equipment to measure drum
concentrations spares drycleaners an expense of $300 to $400.
IFI also noted that the above rule interpretations apply to area-source
facilities that are not co-located within
“mixed use commercial/residential” zoning. Other rules govern those businesses. Cleaners in those situations who
need assistance can contact IFI, (800) 638-2627.
A formal notice of the rules clarifications should be issued by EPA in the near
future, IFI said. In particular, state regulatory officials who have
responsibility for enforcement will need to be advised of these interpretations
of the clean-air rules.
Last year’s amendments to the 1993 clean-air rules for perc drycleaners banned new perc
installations in co-residential locations
— cleaners located in the same buildings as residences. Existing locations have
until 2020 to convert to a non-perc alternative.
For the vast majority of the nation’s drycleaners, the main requirement of the amended rules is the use of
halogenated carbon leak detectors for monthly leak detection. This is in
addition to the already required weekly inspection for leaks that can be
spotted without measuring instruments.
The handful of cleaners — EPA estimated there were about 200 at the time of the rule adoption — still using transfer machines were given two years to replace those machines
with new, closed-loop models.
