AIR TOXICS - TITLE III CAA NESHAP. (National Emission Standards For Hazardous Air Pollutants)

Transcription

1 AIR TOXICS - TITLE III CAA PERC DRY CLEANING NESHAP (National Emission Standards For Hazardous Air Pollutants) Office of Air Quality Planning and Standards Office of Air and Radiation August 1993

2 1 PWC Dry Cleaning NESHAP OUTLINE o Background - Court Order Deadline - Clean Air Act Requirements - Dry Cleaning Industry o Proposal - Basis for Proposal - Summary of Proposal - Public Comments Received o Promulgation - Significant Changes to Proposal - Remaining Issues - Follow Up -1-

3 Background COURT ORDER o Agency Under Court Order - Must promulgate NESHAP by September 13 - Already received two extensions + December 15, > July 15, July 15, > September 13, 1993 o Project Schedule to Meet Court Order - Work Group Closure August 10 - Package to OMB August 20 - OMB Review Complete September 3 - Administrator Signature September 13 o Will Be Very Difficult -2-

4 Background CLEAN AIR ACT o Clean Air Act Requires Development of NESHAP's - List of 189 chemicals - Requirements differ for "Major" and "Area" sources o Major Sources - Sources which emit more than 10 tons/yr - NESHAP must be based on MACT + maximum achievable control technology + new sources - best similar source + existing sources - best 12% of similar sources o Area Sources - Sources which emit less than 10 tons/yr - NESHAP may be based on MACT or GACT - GACT + generally available control technology + no minimal requirements + much greater flexibility -3-

5 PWC Dry Cleaning NESHAP Background CLEAN AIR ACT o Perchloroethvlene (Perc) - Primary solvent used by dry cleaning industry - On list of 189 chemicals - Dry cleaning primary source of perc emissions in United States o Large Number of Dry Cleaners - 32,000 dry cleaning machines - 1% are major sources - 99% are area sources o Regul ation Carries Potential For Small Business Impacts - All dry cleaners small businesses - Many family owned and operated - Most have small cash flow and marginal profitability + average sales: 140,00O/yr + average profitability: 7% return -4-

6 Background EMISSIONS o Two Types of Dry Cleaning Machines - Dry-to-dry (one machine - washer and dryer, combined) - Transfer (two machines - washer and dryer, separate) o Several Sources of Emissions - Process vent from machines - Equipment leaks - Clothing transfer o Control Techniques Source Process vent Clothing transfer Equipment leaks Control Refrigerated condenser or carbon adsorber Transfer enclosure Leak detection/repair o Focus is Pollution Prevention - Refrigeratedcondenser/carbon adsorber and transfer enclosures collect perc emitted and recycle it - Leak detection/repair finds leaks and repairs them to prevent perc emissions -5-

7 Proposal BASIS o Small Business Concerns Dominated Discussions at Proposal - GACT selected as basis for regulation - Alternatives considered to exempt smallest dry cleaners o Impacts of Alternatives Annual Receipts Financial ($ per year) Failures >250,000 >100, 000 > 75, > 50,000 1,030 > 25,000 2,290 > 0 5, 480 Closures ,250 o Effectiveness of Alternatives Annual Receipts ($ per year) >250,000 5, 600 >l00,000 8,300 > 75,000 8, 600 > 50,000 9,000 > 25,000 9,400 > 0 9, 700 Emission cost Reduction Machines Effectiveness (Tons per Year) Covered ($ per Ton) 5, ,200 1, ,900 20,500 24,800 31,600 2,600 4,800 8,400 24,900-6-

8 Proposal SUMMARY o Proposed Controls - Refrigerated condenser or carbon adsorber for process vent(s) - Transfer enclosure for clothing transfer (new transfer machines only) - Leak detection/repair for equipment leaks o Dry Cleaners Covered - New dry cleaners + major sources - all + area sources - all - Existing dry cleaners + major sources - all + area sources - largest only o Small Existing Drycleaners Exempted - All existing area sources below the level of $100,000 gross annual receipts exempted - Exempts ONE-HALF of all existing sources - Only exempts 15% of total perc emissions -7-

9 PROPOSAL PUBLIC COMMENT o Dry Cleaning Trade Associates - Want comprehensive national regulation + states and locals regulating dry cleaners everywhere + want single national and consistent regulation - Cover small dry cleaners exempted - Ban new transfer machines o Environmental Groups - Cover small dry cleaners exempted - Ban new transfer machines and phase-out existing - Ban new carbon adsorbers and phase-out existing o States and Locals - Cover small dry cleaners exempted - Ban new transfer machines and phase-out existing - Ban new carbon adsorbers and phase-out existing -8-

10 Promulgation SIGNIFICANT CHANGES o NESHAP Will Cover Small Existing Dry Cleaners - Annual receipts more than $75,000 + process vent control + leak detection/repair for equipment leaks - Annual receipts less than $75,000 + leak detection/repair for equipment leaks o Bans New Transfer Machines - Transfer machines have greater emissions - No new transfer machines - Phase-out of existing machines considered unreasonable + CAA limits any phase-out to 3 years + imposes major cost for new machine o Bans New Carbon Adsorbers - Refrigerated condensers achieve greater emission reduction - No new carbon adsorbers - Phase-out of existing adsorbers considered unreasonable + CAA limits any phase-out to 3 years + imposes major cost for new control device -9-

11 Promulgation REMAINING ISSUES o Indoor Air Pollution - Issue came to light following proposal - New York measured perc concentrations in apartments located above six small dry cleaners - Concentrations suggest risks in range of l0-2 to l0-4 o Fugitive Emissions Are The Key - Process emissions vented outside and perc concentrations unrelated to whether apartment windows open or closed - "Problem" related to fugitive emissions + equipment leaks + transfer machines + other o "Solution" Not Obvious - Need to gather additional information - Work with trade associations, dry cleaners, State/local agencies

12 Promulgation REMAINING ISSUES o Ground Water Contamination - Issue came to light following proposal - California tested drinking water from 2,000 wells - Found 47 wells with perc concentrations exceeding maximum contaminant level (MCL) o Dry Cleaners Are The Source - Ground water movement and soil gas analysis trace source of contamination to: + sewer lines in most cases + "hot" spots in other cases - Only perc users connected to sewer lines were dry cleaners - All "hot" spots around dry cleaners - "Problem" related to disposal of dry cleaning wastes + sludges/residues + waste water + other - Need to gather additional information - Work with trade associations, dry cleaners, State/local agencies

13 Promulgation FOLLOW-UP o Convene Public Meeting - Mid November probably in New York - Solicit information on potential solutions o Additional Study/Analysis May Follow - Visit sites to assess various solutions - Joint study with trade associations, dry cleaners, State/local agencies o Further Action May Be Appropriate - Guidance documents - Case study reports - Federal regulation

14 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Office of Air Quality Planning and Standards Research Triangle Park, North Carolina NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM PERCHLOROETHYLENE DRY CLEANING FACILITIES--FINAL RULE BACKGROUND FACT SHEET Dry cleaners are major source of perchloroethylene (PCE or "perc"), one of the toxic air pollutants Congress has required the EPA to regulate under the Clean Air Act Amendments of Perchloroethylene is suspected of causing cancer. Under Section 112 of the Clean Air Act, the EPA proposed national emission standards for hazardous air pollutants (NESHAP) to limit PCE emissions from both new and existing dry cleaning facilities on December 9, 1991, the first of several rules the EPA will be issuing to control emissions of air toxics. In response to public comments received on the proposed NESHAP, the EPA published a notice of availability of new information on control of PCE emissions during clothing transfer at dry cleaning facilities using transfer dry cleaning machines on October 1, Additional comments were received. REQUIREMENTS OF EPA DRY CLEANERS RULE The rule breaks dry cleaners into three separate categories--small "area" sources, large "areal" sources, and "ma jor" sources--and contains ' different requirements for each category. (See Table 1.) There are two types of dry cleaning machines: dry-to-dry and transfer. A dry-to-dry machine consists of one machine, which does both the washing and the drying of the articles being cleaned. A transfer machine consists of two machines: a washer and a dryer. Clothing is transferred from the washer to the dryer at transfer machines, and this step is a significant source of PCE emissions. The EPA's final rule requires all new dry cleaning machines to be dry-to-dry machines. It does not, however, require the replacement of existing transfer machines with new dry-to-dry machines. 1 of 6

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17 There are two sources of PCE emissions at dry cleaning facilities: process vent emissions (i.e., the dry cleaning machine vent); and fugitive emissions (e.g., clothing transfer at transfer machines, equipment leaks, open containers, etc. ). Process vent emissions are controlled through the use of refrigerated condensers or carbon adsorbers. Fugitive emissions from clothing transfer at transfer machines are controlled through room enclosures. Other fugitive emissions are controlled through leak detection/repair, and pollution prevention activities (e.g., good housekeeping). The EPA's rule requires control of process vent emissions at all new dry cleaning facilities. It also requires control of process vent emissions at large area source and major source existing dry cleaning facilities. The rule requires control of fugitive emissions at all new dry cleaning facilities. It also requires control of fugitive emissions at all existing dry cleaning facilities, with the exception of fugitive emissions from clothing transfer at transfer machines. Only transfer machines at major source existing dry cleaning facilities are required to control fugitive emissions from clothing transfer. The rule requires the use of refrigerated condensers to control process vent emissions at new dry cleaning facilities. It also requires the use of refrigerated condensers to control process vent emissions at existing dry cleaning facilities, except those existing facilities that have already installed a carbon adsorber for control of process vent emissions. Existing dry cleaning facilities that currently use a carbon adsorber may continue to use this carbon adsorber to comply with the requirements of the rule. All new dry cleaning facilities must comply with the new EPA rule when they begin operation. Existing dry cleaning facilities have 36 months to comply. IMPACTS Nationwide Impacts - In 1996 about 25,000 commercial and industrial dry cleaning facilities will be in operation. Although the dry cleaning industry exhibits little growth, about 7,700 of these 25,000 facilities will be new facilities built to replace existing facilities that retire. Of these 7,700 new facilities, about 400 would likely be uncontrolled 4 of 6

18 in the absence of the rule and, as a result of the rule, will be required to install process vent control. In addition, the EPA rule will require about 3,200 existing uncontrolled facilities to install controls on process vents. - The rule will result in a total maximum national emissions reduction of perchloroethylene of 6,600 megagrams (Mg) (7,300 tons) from process vent control and 25,800 Mg (28,400 tons) from leak detection and repair (LDAR) from projected 1996 emission levels. - Energy: Total maximum national increase in e1ectricity use (needed to operate the control devices) of 0.28 gigawatt hours per year (GWh/yr) in 1996 for new facilities and 2.5 Gwh/yr for existing facilities. - Annualized Cost: Total national increase of $3.9 million/year for process vent control in 1996, if solvent savings are included. Total national increase of $9.0 million in 1996, if solvent savings are not included. Total national cost savings of $7.6 million for LDAR, if cost savings are included. Total national increase of $10.0, if solvent savings are not included. - Capital Cost: Total national increase of $3 million for new dry cleaning, facilities and $32 million for existing dry cleaning facilities in Typical facility impacts for an existing, uncontrolled, 35-pound dry-to-dry machine located at an area source dry cleaning facility that would have to install a refrigerated condenser would be as follows: - Perchloroethylene Emission Reductions: Individual reduction of 0. 8 Mg/yr (0.9 tons per year) from process vent control and 0.8 Mg/yr (0.9 tons per year) from LDAR from projected 1996 emission levels. - Wastewater: Total maximum increase of 0.03 kilograms/yr (0.07 pounds per year) of PCE in wastewater in Solid Waste: No increase for the typical facility. - Noise:. No incremental impacts. 5 of 6

19 - Energy: The increase in electricity use (needed to operate refrigerated condenser) of 604 kilowatt hours per year in 1996, - Annualized Cost: Increase of $1,100/year for process vent control and $460/year for LDAR, monitoring, reporting, and recordkeeping. - Capital Cost: On the average an increase of $6,300/year for those who are required to put on process vent controls, 6 of 6