Workshop for Perchloroethylene (Perc) Dry Cleaner

Joe Panetta, Environmental Specialist III Air Resource Management Southwest District Office September 30, 2010

Mara Nasca Air Program Administrator Danielle D. Henry Air Compliance Manager Cindy Falandysz Air Enforcement Manager Joe Panetta Air Program Environmental Specialist III 2

• How Dry Cleaning was Discovered • Perchloroethylene (PERC) dry cleaning facility requirements per Rule 62-213.300(1) (a), Florida Administrative Code, (F.A.C.) • Health Effects from Perc • Registration Requirements in DEP Form No. 62 213.300(1)(a), F.A.C. • (Code of Federal Regulation) 40CFR 63.320

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Southwest District Air Program has Approximately 40 Perc Dry Cleaner Facilities that are registered with an Air General Permit 4

** Additional Rules may be required by Hillsborough, Pinellas and Sarasota Counties 5

 Dry Cleaning § 63.321 Definitions.

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Dry cleaning means the process of cleaning articles using perchloroethylene.

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Dry cleaning came about by accident. In 1855, Jean Baptiste Jolly, a French dye works owner, who noticed that his tablecloth became cleaner after his maid spilled

kerosene

(paraffin) on it. He later developed a service cleaning people's clothes in this manner, which became known as "nettoyage à sec," or "dry cleaning“.

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 Doing laundry has been a common household activity for years. Whether the technology was beating the garments on rocks by the river or pushing buttons on programmed washing machines , this process depends on water and a mechanical action usually assisted by soap or an alkali. The purpose of an alkali is to saponify the oils and dislodge ordinary soil and other matter. More often than not, the soapy agent holds soil in suspension as it becomes loose during the wash cycle, and is subsequently flushed away during the rinse cycle and centrifugal spin.  The drying process for doing laundry at home is either hanging clothes on a clothesline or tumbling them in a gas or electric-heated dryer . 8

Dry cleaning, on the other hand, is different. It's a process that cleans clothes without water. The cleaning fluid that is used is a liquid, and all garments are immersed and cleaned in a liquid solvent -- the fact that there is no water is why the process is called "dry.” 9

 Early dry cleaners used a variety of solvents including gasoline and kerosene to clean clothes and fabrics. In the United States, the dry-cleaning industry is fairly new and has developed only during the past 75 years. Since World War II ended, the volatile synthetic solvents carbon tetrachloride and trichlorethylene gave way to a product known as perchlorethylene (perc), which became the overwhelming solvent choice for the industry. It was not only safer and faster, but did a much better job of cleaning, required less massive equipment, less floor space, and could be installed in retail locations offering excellent quality one-hour service. 10

As a result of this innovation, the majority of clothes today are cleaned by perc. A proliferation of cleaning franchises and dry cleaning businesses offering fast service from convenient, clean, and attractive locations evolved to change the industry into what we see today. 11

Perc is classified as a hazardous air contaminant by the United States Environmental Protection Agency and must be handled as a hazardous waste smog . To prevent it from getting into drinking water, dry cleaners that use perc must take special precautions against site contamination. Landlords are becoming increasingly reluctant to allow dry cleaners to operate in their buildings. When released into the air, perc can contribute to when it reacts with other volatile organic carbon substances 12

 Perc is readily absorbed into the bloodstream both through inhalation and after oral exposure.

 Dermal uptake appears to be complete but slower than other routes of exposure.  From the bloodstream, perc distributes readily into fatty tissues and some accumulate there.  Perc also crosses the placental barrier.  Perc is mostly exhaled unchanged. Regardless of the route of exposure, 1-3% of the absorbed PERC is metabolized. 13

The primary route of exposure to PERC is inhalation. 14

 Once taken into the body, some perc can be excreted through exhalation or (after metabolization) through urine.  Metabolized into TCA trichloroacetictrichloroaceticacid 15

What is the purpose of the Perchloroethylene Dry Cleaner Air General Permit Notification Form?

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The use of an Air General Permit notification form serves a several purposes:  Provides notice to the Department that the facility is in operation and  Prescribes the requirements under which the facility is allowed to operate [Rule 62-296.310(5)(b), F.A.C.] 17

Perchloroethylene (PERC) Dry Cleaning - Rule Requirements

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Perchloroethylene (PERC) Dry Cleaning - Rule Requirements

A perchloroethylene dry cleaning facility may provided the: use a air general permit  facility meets the eligibility criteria set forth in the rule and, throughout the term of the general permit  maintains its eligibility to use the general permit and complies with all terms and conditions of the general permit.  The responsible official of the perchloroethylene dry cleaning facility shall determine the facility’s eligibility for the Air General Permit and notify the Department of intent to use the Air General Permit .

Rule 62-213.300(1)(a), F.A.C.

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A perchloroethylene dry cleaning facility is eligible to operate under the terms and conditions of the Air General Permit established at Rule 62-213.300(1)(a), F.A.C.,  provided the responsible official has submitted a completed Part III of this notification form to the Department at least 30 days prior to beginning operations under the general permit  and throughout the term of the general permit, all of the following conditions are met: 20

 The facility operates no emissions units other than perchloroethylene dry cleaning systems and emissions units which are considered insignificant pursuant to the criteria of Rule 62-213.300(2)(a)1., F.A.C., set forth in paragraph (1)(b);  The facility is classified as a small or large area source pursuant to 40 CFR Part 63, and 21

 The facility complies with all general conditions of Rule 62-213.300(3) 22

Notification:  For each facility intending to operate under the provisions of this Air General Permit, the responsible official must complete and submit Part III of this Perchloroethylene Dry Cleaner Air General Permit Notification Form [DEP Form No. 62-213.900(2), F.A.C.] to give notice to the Department of intent to use such permit.

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Administrative Corrections: a) Any change in name of the responsible official or facility address or phone number; b) A change in facility status requiring more frequent monitoring or reporting by the responsible official from that noted on the most recent notification form; and c) Any other similar minor administrative change at the facility.

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Violation of Permit.  This Air General Permit is valid only for the specific activity indicated.

 Any deviation from the specified activity and the conditions for undertaking that activity is a violation of the permit  Violation of the permit constitutes grounds for revocation  Initiation of enforcement action  No revocation shall become effective except after notice is served by personal service, certified mail, or newspaper notice 25

Nullification of Eligibility. Eligibility for use of a t his Air General Permit is automatically nullified by:  Submission of false or inaccurate information in the notification form for use of the Air General Permit or in the required reports;  Refusal of lawful inspection by Department staff;  Failure to submit operational reports or other information required by the Air General Permit ; or  Failure to timely pay the required fee, penalty, or interest.

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Perchloroethylene (PERC) Dry Cleaning Part II - Rule Requirements

General Conditions [Rule 62-210.310(3), F.A.C.]

The duration of this general permit is five years. No later than 30 days prior to the fifth anniversary of the filing of intent to use this general permit, the responsible official shall submit a new notice of intent which shall contain all current information regarding the facility. The general permit is not transferable and does not follow a change in ownership of the facility. Prior to any sale, other change of ownership, or permanent shutdown of the facility, the responsible official shall notify the Department.

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The responsible official shall make every reasonable effort to conduct the specific activity authorized by this general permit in a manner that will minimize any adverse effects on adjacent property or on public use of the adjacent property, where applicable, and on the environment, including fish, wildlife, natural resources, water quality, or air quality .

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The responsible official shall allow a duly authorized representative of the Department access to the permitted facility or activity at reasonable times to inspect and test, upon presentation of credentials or other documents as may be required by law, to determine compliance with this Air General Permit and Department rules.

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Monitoring and Related Recordkeeping and Reporting Requirements.

The responsible official shall maintain records of monitoring information that specify the date, place, time, and operating conditions of measurement; the methodology used; the company or entity which performed the monitoring; and the analytical results. These shall include all calibration and maintenance records, original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit.

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The responsible official shall retain records of all monitoring data and supporting information for a period of at least five years from the date of collection.

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§ 63.320 Applicability (a) applies to operatoring dry cleaning facility using perc (b) The compliance date for a new dry cleaning system depends on the date that construction or reconstruction commences.

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§ 63.322 Standards

The owner or operator shall cleaning machine other times.

immediately close the door of each dry after transferring articles to or from the machine, and shall keep the door closed at all The owner or operator of each dry cleaning system shall operate and maintain the system according to the manufacturers' specifications and recommendations .

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§ 63.322 Standards Continued The owner or operator of a dry cleaning system shall inspect the system weekly for perceptible leaks while the dry cleaning system is operating. Inspection with a halogenated hydrocarbon detector or PCE gas analyzer also fulfills the requirement for inspection for perceptible leaks. The following instrument is used to inspect the drycleaning system: 35

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§ 63.322 Standards Continued (1) Hose and pipe connections, fittings, couplings, and valves; (2) Door gaskets and seatings; (3) Filter gaskets and seatings; (4) Pumps; (5) Solvent tanks and containers; 37

63.322 Standards Continued (6) Water separators (7) Muck cookers (8) All Filter housings (9) Exhaust dampers (10) Diverter valves (11) Stills 38

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INSPECTIONS : If you buy 140 gallons or more of PERC per year, you must check your machine weekly for leaks and record the results.

If you buy less than 140 gallons of PERC per year, you must conduct and record leak inspections at least every other week.

Record the results of the inspections on the calendar. If leaks are found, they must be repaired within 24 hours. Indicate in the “DATE REPAIRED” block when repairs are completed. If parts must be purchased, indicate the dates they are ordered and the date installed. Parts must be ordered within 2 working days of leak detection and installed within 5 working days of receipt.

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http://www.dep.state.fl.us/air/emission/sbeaplib/dry_cleaner_2010.pdf

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 If the facility installs new process or air pollution control equipment, alters existing process or control equipment without replacement, or replaces existing process or control equipment with equipment substantially different than owner or operator shall submit a new and appropriate AG permit processing fee of presentation.

that noted on the most recent registration form, the complete AG permit registration form with the $100.00 to the Tallahassee addresses listed later in the 46

 Submitting your Registration Form

for OVERNIGHT DELIVERY: (FedEx, UPS, DHL, etc.)

FDEP 3800 COMMONWEALTH BLVD, MS-77 TALLAHASSEE, FLORIDA 32399 47

…for regular USPS MAIL DELIVERY: (U.S. Mail)

FDEP RECEIPTS POST OFFICE BOX 3070 TALLAHASSEE, FLORIDA 32315-3070

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Marnie Brynes Division of Air Resource Management Air General Permits Program (850) 922-8978 [email protected]

or Stephen McKeough Small Business Environmental Assistance Program Ombudsman 1-800-722-7457 or (850) 921-9539 [email protected]

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http://www.dep.state.fl.us/southwest/contacts/ 50

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 The Title V yearly statement of compliance forms are not going to be required when the TV GP’s are moved into Non TV GP’s. If the NESHAP requires some frequency of compliance reporting, that will still be required.

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 There are no more annual fees for these facilities. The last annual fee was billed in December 2006 with a payable date in March 2007. Once the rule is finalized the $100 registration fee will apply.

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 we are anticipating the rule revisions to be final sometime in the 1 st quarter of 2011.

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 Questions  Questions  Questions  Thank you…..

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