Economic
Impact
Analysis
of
the
Proposed
Halogenated
Solvent
Cleaners
Residual
Risk
Standard
2
EPA­
452/
R­
06­
006
August
2006
Economic
Impact
Analysis
of
the
Proposed
Halogenated
Solvent
Cleaners
Residual
Risk
Standard
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Health
and
Environmental
Impacts
Division
Air
Benefits
and
Costs
Group
Research
Triangle
Park,
NC
3
4
Executive
Summary
The
EPA
is
proposing
a
revised
standard
to
reduce
the
amount
of
risk
associated
with
exposure
to
methylene
chlorine
(
MC),
perchloroethylene
(
PCE),
and
trichloroethylene
(
TCE)

from
existing
and
new
halogenated
solvent
cleaning
machines.
This
standard
will
revise
current
limits
on
these
emissions
from
such
machines.
EPA
promulgated
a
maximum
achievable
control
technology
(
MACT)
standard
in
1994
to
set
emission
limits
on
these
three
pollutants
to
reduce
such
emissions.
The
proposed
standard
will
revise
these
limits
based
on
a
finding
that
sufficient
residual
risk
exists
to
warrant
a
tighter
standard.

This
report
provides
the
economic
impacts
associated
with
this
proposed
standard.
We
provide
economic
impacts
for
six
different
regulatory
options
considered
for
the
proposal.
Two
of
these
options
will
be
proposed
as
part
of
this
standard.
The
impacts
in
this
report
are
estimated
based
on
comparisons
of
annualized
compliance
costs
to
the
revenues
for
affected
firms.
We
find
that
the
impacts
of
these
options
are
generally
minimal
to
small
businesses
except
for
the
most
stringent
scenario
(
known
as
Regulatory
Option
6),
and
that
large
businesses
should
experience
cost
savings
for
the
most
part.
We
find
that
small
firms
are
66
percent
of
the
businesses
affected
under
each
of
the
options
considered
in
this
analysis.
These
impacts
range
from
only
5
firms
(
4
small)
out
of
281
(
186
small)
having
some
positive
cost
to
sales
estimate
for
the
least
stringent
option
(
known
as
Regulatory
Option
Scenario
1)
to
146
firms
(
124
small)
that
have
some
positive
cost
to
sales
estimate,
with
8
small
firms
out
of
these
124
having
annualized
compliance
costs
of
greater
than
3
percent
of
sales.
For
the
proposed
options,
Regulatory
Option
Scenarios
3
and
4,
the
impacts
range
from
9
firms
(
6
small)
that
have
some
positive
cost
to
sales
estimate
to
38
firms
(
32
small)
that
have
a
positive
cost
to
sales
estimate.
There
is
no
significant
economic
impact
on
a
substantial
number
of
small
entities
(
or
SISNOSE)
under
either
of
the
proposed
options.
5
Introduction
The
EPA
is
proposing
revised
standards
to
limit
emissions
of
methylene
chloride
(
MC),

perchloroethylene
(
PCE),
and
trichloroethylene
(
TCE)
from
existing
and
new
halogenated
solvent
cleaning
machines.
In
1994,
EPA
promulgated
technology­
based
emission
standards
to
control
emissions
of
methylene
chloride
(
MC),
perchloroethylene
(
PCE),
trichloroethylene
(
TCE),
1,1,1­
trichloroethane
(
TCA),
carbon
tetrachloride
(
CT),
and
chloroform
(
C)
from
halogenated
solvent
cleaning
machines
(
59
FR
61801,
December
2,
1994).
Pursuant
to
the
Clean
Air
Act
(
CAA)
section
112(
f),
EPA
has
evaluated
the
remaining
risk
to
public
health
and
the
environment
following
implementation
of
the
technology­
based
rule
and
is
proposing
more
stringent
standards
in
order
to
protect
public
health
with
an
ample
margin
of
safety.
In
addition,

EPA
has
reviewed
the
standards
as
required
by
section
112
(
d)(
6)
of
the
CAA
and
has
determined
that,
taking
into
account
developments
in
practices,
processes,
and
control
technologies,
no
further
action
is
necessary
at
this
time
to
revise
the
national
emission
standards.

The
proposed
standards
will
provide
further
reductions
of
MC,
PCE,
and
TCE
beyond
the
1994
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP),
based
on
application
of
a
facility­
wide
MC,
PCE
and
TCE
emission
standards.

Profile
of
Affected
Industries
Halogenated
solvent
cleaners
are
found
in
NAICS
codes
332999,
337124,
335999,
336999,
332116,
336,
339.
A
description
of
each
of
these
NAICS
codes
is
contained
below.

NAICS
332999:
All
Other
Miscellaneous
Fabricated
Metal
Product
Manufacturing
.
This
U.
S.
industry
comprises
establishments
primarily
engaged
in
manufacturing
fabricated
metal
products
(
except
forgings
and
stampings,
cutlery
and
handtools,
architectural
and
structural
metals,
boilers,
tanks,
shipping
containers,
hardware,
spring
and
wire
products,
machine
shop
products,
turned
products,
screws,
nuts
and
bolts,
metal
valves,
ball
and
roller
bearings,
ammunition,
small
arms
and
other
ordnances,
fabricated
pipes
and
pipe
fittings,
industrial
patterns,
and
enameled
iron
and
metal
sanitary
ware).

NAICS
337124:
Metal
Household
Furniture
Manufacturing
.
This
U.
S.
industry
comprises
establishments
primarily
engaged
in
manufacturing
metal
household­
type
furniture
and
freestanding
cabinets.
The
furniture
may
be
made
on
a
stock
or
custom
basis
and
may
be
assembled
or
unassembled
(
i.
e.,
knockdown).
6
NAICS
335999:
All
Other
Miscellaneous
Electrical
Equipment
and
Component
Manufacturing
.
This
U.
S.
industry
comprises
establishments
primarily
engaged
in
manufacturing
industrial
and
commercial
electric
apparatus
and
other
equipment
(
except
lighting
equipment,
household
appliances,
transformers,
motors,
generators,
switchgear,
relays,
industrial
controls,
batteries,
communication
and
energy
wire
and
cable,
wiring
devices,
and
carbon
and
graphite
products).
This
industry
includes
power
converters
(
i.
e.,
AC
to
DC
and
DC
to
AC),
power
supplies,
surge
suppressors,
and
similar
equipment
for
industrial­
type
and
consumer­
type
equipment.

NAICS
336999:
All
Other
Transportation
Equipment
Manufacturing
.
This
U.
S.
industry
comprises
establishments
primarily
engaged
in
manufacturing
transportation
equipment
(
except
motor
vehicles,
motor
vehicle
parts,
boats,
ships,
railroad
rolling
stock,
aerospace
products,
motorcycles,
bicycles,
armored
vehicles
and
tanks).

NAICS
332116:
Metal
Stamping
.
This
U.
S.
industry
comprises
establishments
primarily
engaged
in
manufacturing
unfinished
metal
stampings
and
spinning
unfinished
metal
products
(
except
crowns,
cans,
closures,
automotive,
and
coins).
Establishments
making
metal
stampings
and
metal
spun
products
and
further
manufacturing
(
e.
g.,
machining,
assembling)
a
specific
product
are
classified
in
the
industry
of
the
finished
product.
Metal
stamping
and
metal
spun
products
establishments
may
perform
surface
finishing
operations,
such
as
cleaning
and
deburring,
on
the
products
they
manufacture.

NAICS
336:
Transportation
Equipment
Manufacturing
.
Industries
in
the
Transportation
Equipment
Manufacturing
subsector
produce
equipment
for
transporting
people
and
goods.
Transportation
equipment
is
a
type
of
machinery.
An
entire
subsector
is
devoted
to
this
activity
because
of
the
significance
of
its
economic
size
in
all
three
North
American
countries.

NAICS
339:
Miscellaneous
Manufacturing
.
Industries
in
the
Miscellaneous
Manufacturing
subsector
make
a
wide
range
of
products
that
cannot
readily
be
classified
in
specific
NAICS
subsectors
in
manufacturing.
Processes
used
by
these
establishments
vary
significantly,
both
among
and
within
industries.
For
example,
a
variety
of
manufacturing
processes
are
used
in
manufacturing
sporting
and
athletic
goods
that
include
products,
such
as
tennis
racquets
and
golf
balls.
The
processes
for
these
products
differ
from
each
other,
and
the
processes
differ
significantly
from
the
fabrication
processes
used
in
making
dolls
or
toys,
the
melting
and
shaping
of
precious
metals
to
make
jewelry,
and
the
bending,
forming,
and
assembly
used
in
making
medical
products.

Table
1
provides
percentages
of
the
number
of
firms
and
establishments
(
or
facilities)
that
are
in
the
NAICS
codes
listed
above.
7
Table
1.
Percentage
of
Firms
and
Establishments
with
Less
than
500
Employees
by
NAICS
Code
NAICS
Code
Firms
(%)
Establishments
(%)

332999
97.38%
96.39%

337124
95.87%
90.45%

335999
92.14%
90.40%

336999
94.52%
90.98%

332116
95.11%
92.51%
8
336
94.39%
80.95%

339
98.59%
96.07%

(
Information
obtained
from
Statistics
of
U.
S.
Businesses,
2001,
U.
S.
Census
Bureau.)

We
see
from
this
table
that
these
industries
are
largely
dominated
by
small
businesses
and
establishments
(
or
facilities).

Economic
Growth
for
these
industries:

A
projection
of
the
average
annual
rate
of
change
in
output
from
2002
to
2012
for
4­
digit
NAICS
codes
these
industries
are
found
in
shows
expected
output
increases
ranging
from
1.2
to
5.2
%
(
Monthly
Labor
Review,
Bureau
of
Labor
Statistics,
February
2004).
Thus,
moderate
economic
growth
is
expected
in
these
industries
over
the
next
several
years.

I.
Background
A.
Statutory
authority
for
regulating
hazardous
air
pollutants
(
HAP)

Section
112
of
the
Clean
Air
Act
(
CAA)
establishes
a
two­
stage
regulatory
process
to
address
emissions
of
hazardous
air
pollutants
(
HAP)
from
stationary
sources.
In
the
first
stage,

after
EPA
has
identified
categories
of
sources
emitting
one
or
more
of
the
HAP
listed
in
the
CAA
section
112(
d)
calls
for
us
to
promulgate
national
technology­
based
emission
standards
for
sources
within
those
categories
that
emit
or
have
the
potential
to
emit
any
single
HAP
at
a
rate
of
10
tons
or
more
per
year
or
any
combination
of
HAP
at
a
rate
of
25
tons
or
more
per
year
(
known
as
"
major
sources"),
as
well
as
for
certain
"
area
sources"
emitting
less
than
those
amounts.
These
technology­
based
standards
must
reflect
the
maximum
reductions
of
HAP
achievable
(
after
considering
cost,
energy
requirements,
and
non­
air
health
and
environmental
impacts)
and
are
commonly
referred
to
as
maximum
achievable
control
technology
(
MACT)

standards.

For
area
sources,
CAA
section
112(
d)(
5)
provides
that
the
standards
may
reflect
9
generally
available
control
technology
or
management
practices
in
lieu
of
MACT,
and
are
commonly
referred
to
as
generally
available
control
technology
(
GACT)
standards.

EPA
is
then
required
to
review
these
technology­
based
standards
and
to
revise
them
"
as
necessary,
taking
into
account
developments
in
practices,
processes
and
control
technologies,"

no
less
frequently
than
every
eight
years.

CAA
section
112(
f)(
2)
requires
us
to
determine
for
each
section
112(
d)
source
category
whether
the
MACT
standards
protect
public
health
with
an
ample
margin
of
safety.
If
the
MACT
standards
for
HAP
"
classified
as
a
known,
probable,
or
possible
human
carcinogen
do
not
reduce
lifetime
excess
cancer
risks
to
the
individual
most
exposed
to
emissions
from
a
source
in
the
category
or
subcategory
to
less
than
1­
in­
1
million,"
EPA
must
promulgate
residual
risk
standards
for
the
source
category
(
or
subcategory)
as
necessary
to
provide
an
ample
margin
of
safety.
The
EPA
must
also
adopt
more
stringent
standards
to
prevent
an
adverse
environmental
effect
(
defined
in
CAA
section
112(
a)(
7)
as
"
any
significant
and
widespread
adverse
effect
*
*
*

to
wildlife,
aquatic
life,
or
natural
resources
*
*
*."),
but
must
consider
cost,
energy,
safety,
and
other
relevant
factors
in
doing
so.

B.
Halogenated
solvent
cleaning
 
process
background
Halogenated
solvent
cleaning
machines
use
halogenated
solvents
(
methylene
chloride,

perchloroethylene,
trichloroethylene,
1,1,1,­
trichloroethane,
carbon
tetrachloride,
and
chloroform),
halogenated
solvent
blends,
or
their
vapors
to
remove
soils
such
as
grease,
oils,

waxes,
carbon
deposits,
fluxes,
and
tars
from
metal,
plastic,
fiberglass,
printed
circuit
boards,
and
other
surfaces.
Halogenated
solvent
cleaning
is
typically
performed
prior
to
processes
such
as
painting,
plating,
inspection,
repair,
assembly,
heat
treatment,
and
machining.
Types
of
solvent
cleaning
machines
include,
but
are
not
limited
to,
batch
vapor,
in­
line
vapor,
in­
line
cold,
and
batch
cold
solvent
cleaning
machines.
Buckets,
pails,
and
beakers
with
capacities
of
7.6
liters
(
2
gallons)
or
less
are
not
considered
solvent
cleaning
machines.

Halogenated
solvent
cleaning
does
not
constitute
a
distinct
industrial
category,
but
is
an
integral
part
of
many
major
industries.
Based
on
data
in
our
National
Emissions
Inventory
(
NEI),
the
five
3­
digit
NAICS
Code
that
use
the
largest
quantities
of
halogenated
solvents
for
cleaning
are
NAICS
337
(
furniture
and
related
products
manufacturing),
NAICS
332
(
fabricated
metal
manufacturing),
NAICS
335
(
electrical
equipment,
appliance,
and
component
manufacturing),
NAICS
336
(
transportation
equipment
manufacturing),
and
NAICS
339
10
(
miscellaneous
manufacturing).
Additional
industries
that
use
halogenated
solvents
for
cleaning
include
NAICS
331
(
primary
metals),
NAICS
333
(
machinery),
and
NAICS
334
(
computer
and
electronic
equipment
man.).
Non­
manufacturing
industries
such
as
railroad
(
NAICS
482),
bus
(
NAICS
485),
aircraft
(
NAICS
481),
and
truck
(
NAICS
484)
maintenance
facilities;
automotive
and
electric
tool
repair
shops
(
NAICS
811);
and
automobile
dealers
(
NAICS
411)
also
use
halogenated
solvent
cleaning
machines.

We
estimated
that
there
were
approximately
16,400
batch
vapor,
8,100
in­
line,
and
perhaps
as
many
as
100,000
batch
cold
cleaning
machines
in
the
U.
S.
prior
to
promulgation
of
the
MACT
standards.
More
recent
information
shows
that
the
current
number
of
cleaning
machines
is
much
lower
than
these
pre­
MACT
estimates.
We
currently
estimate
the
number
of
sources
in
this
source
category
to
be
about
3,800
cleaning
machines
located
at
1,900
facilities
in
the
U.
S.
This
estimate
is
based
on
information
we
collected
in
1998,
a
year
after
compliance
with
the
MACT
occurred
and
should
reflect
the
decreases
in
HAP
emissions
and
demand
that
were
expected
due
to
implementation
of
MACT
control
technologies
and
work
practice
standards.
Recent
evidence
on
solvent
usage
suggests
that
the
number
of
sources
in
the
source
category
may
have
declined
further
in
the
post­
MACT
implementation
years.
An
analysis
of
market
data
for
halogenated
solvents
showed
that
the
demand
for
degreasing
solvents
declined
substantially
in
the
five
years
following
the
implementation
of
MACT.
From
1998
to
2003,
the
demand
for
tetrachloroethylene,
trichloroethylene,
methylene
chloride,
and
1,1,1­
trichloroethane
for
degreasing
decreased
by
39
percent,
35
percent,
23
percent,
and
15
percent,
respectively.

There
are
two
basic
types
of
solvent
cleaning
machines:
batch
cleaners
and
in­
line
cleaners.
Both
cleaner
types
can
be
designed
to
use
either
solvent
at
room
temperature
(
cold
cleaners)
or
solvent
vapor
(
vapor
cleaners).
The
vast
majority
of
halogenated
solvent
use
is
in
vapor
cleaning,
both
batch
and
in­
line.
The
most
common
type
of
batch
cleaner
that
uses
halogenated
solvent
is
the
open­
top
vapor
cleaner
(
OTVC).

Batch
cleaning
machines,
which
are
the
most
common
type,
are
defined
as
a
solvent
cleaning
machine
in
which
individual
parts
or
sets
of
parts
move
through
the
entire
cleaning
cycle
before
new
parts
are
introduced.
Batch
cleaning
machines
include
cold
and
vapor
machines.
In
batch
cold
cleaning
machines,
the
material
being
cleaned
(
i.
e.,
the
workload)
is
immersed,
flushed,
or
sprayed
with
liquid
solvent
at
room
temperature.
Most
batch
cold
cleaners
are
small
maintenance
cleaners
(
e.
g.,
carburetor
cleaners)
or
parts
washers
that
often
use
non
11
HAP
solvent
mixtures
for
cleaning.
Batch
cold
cleaning
equipment
sometimes
includes
agitation
to
improve
cleaning
efficiency.

In
batch
vapor
cleaning
machines,
parts
are
lowered
into
an
area
of
dense
vapor
solvent
for
cleaning.
The
most
common
type
of
batch
vapor
cleaner
is
the
open­
top
vapor
cleaner.

Heating
elements
at
the
bottom
of
the
cleaner
heat
the
liquid
solvent
to
above
its
boiling
point.

Solvent
vapor
rises
in
the
machine
to
the
height
of
chilled
condensing
coils
on
the
inside
walls
of
the
cleaner.
The
condensing
coils
cool
the
vapor
causing
it
to
condense
and
return
to
the
bottom
of
the
cleaner.
Cleaning
occurs
in
the
vapor
zone
above
the
liquid
solvent
and
below
the
condensing
coils,
as
the
hot
vapor
solvent
condenses
on
the
cooler
workload
surface.
The
workload
or
a
parts
basket
is
lowered
into
the
heated
vapor
zone
with
a
mechanical
hoist.

Batch
vapor
cleaning
machines
vary
greatly
in
size
and
design
to
suit
applications
in
many
industries.
Batch
vapor
cleaner
sizes
are
defined
by
the
area
of
the
solvent/
air
interface.

Emissions
from
batch
cold
cleaning
machines
result
from
evaporation
of
solvent
from
the
solvent/
air
interface,
"
carry
out"
of
excess
solvent
on
cleaned
parts,
and
other
evaporative
losses
such
as
those
that
occur
during
filling
and
draining.
Evaporative
emissions
from
the
solvent/
air
interface
are
continual
whether
or
not
the
machine
is
in
use.
These
evaporative
losses
can
be
reduced
by
limiting
air
movement
over
the
solvent/
air
interface
(
e.
g.,
with
a
machine
cover
or
by
reducing
external
drafts)
or
by
limiting
the
area
of
solvent
air
interface
(
e.
g.,
with
a
floating
water
layer).
Emissions
related
to
solvent
carry
out
occur
only
when
the
cleaning
machine
is
in
use.

The
closed­
loop
cleaning
system
is
a
type
of
batch
cleaner
with
a
closed
system
capable
of
reusing
solvent.
Parts
are
placed
inside
a
vacuum
chamber.
Vapor
or
liquid
solvent
is
pumped
in
the
chamber
to
clean
the
parts.
Once
cleaned,
the
parts
are
dried
under
vacuum
and
removed;

the
solvent
is
removed
and
recycled.
Because
these
systems
are
constructed
to
maintain
a
vacuum,
they
have
the
potential
to
reduce
emissions
up
to
97
percent.

Cold
and
vapor
in­
line
(
i.
e.,
conveyorized)
cleaning
machines,
which
include
continuous
web
cleaners,
employ
automated
parts
loading
and
are
used
in
applications
where
there
is
a
constant
stream
of
parts
to
be
cleaned.
In­
line
cleaners
usually
are
used
in
large­
scale
industrial
operations
(
e.
g.,
auto
manufacturing)
and
are
custom­
designed
for
specific
workload
and
production
characteristics
(
e.
g.,
workload
size,
shape,
and
production
rate).
In­
line
cleaners
clean
parts
using
the
same
general
techniques
used
in
batch
cleaners:
cold
in­
line
cleaners
spray
12
or
immerse
parts
in
solvent,
and
vapor
in­
line
cleaners
clean
parts
in
a
zone
of
dense
vapor
solvent.

Emissions
from
cold
and
vapor
in­
line
cleaning
machines
result
from
the
same
mechanisms
(
e.
g.,
evaporation,
diffusion,
carryout)
that
cause
emissions
from
cold
and
vapor
batch
cleaning
machines.
However,
the
emission
points
for
in­
line
cleaners
are
different
from
those
for
batch
cleaners
because
of
differences
in
machine
configurations.
In­
line
cleaning
machines
are
semi­
enclosed
above
the
solvent/
air
interface
to
control
solvent
losses.
In
most
cases,
the
only
openings
are
the
parts
entry
and
exit
ports.
These
openings
are
the
only
emissions
points
for
downtime
and
idling
modes.
Carryout
emissions
add
to
emissions
during
the
working
mode.
Idling
and
working
mode
emissions
from
the
in­
line
cleaner
are
significantly
less
than
emissions
from
an
equally­
sized
batch
vapor
cleaner.
However,
in­
line
cleaners
tend
to
be
much
larger
than
batch
vapor
cleaners.
Some
in­
line
cleaners
have
exhaust
systems
that
pump
air
from
inside
the
cleaning
machine
to
an
outside
vent.
Exhaust
systems
for
in­
line
cleaners
reduce
indoor
emissions
from
the
cleaning
machine
but
increase
solvent
consumption.

Continuous
cleaners
are
a
subset
of
in­
line
cleaners
and
are
used
to
clean
products
such
as
films,
sheet
metal,
and
wire
in
rolls
or
coils.
The
workload
is
uncoiled
and
conveyorized
throughout
the
cleaning
machine
at
speeds
in
excess
of
11
feet
per
minute
and
recoiled
or
cut
as
it
exits
the
machine.
Emission
points
from
continuous
cleaners
are
similar
to
emission
points
from
other
inline
cleaners.
Continuous
cleaners
are
semi­
enclosed,
with
emission
points
where
the
workload
enters
and
exits
the
machine.
Squeegee
rollers
reduce
carry
out
emissions
by
removing
excess
solvent
from
the
exiting
workload.
Some
continuous
machines
have
exhaust
systems
similar
to
those
used
with
some
other
in­
line
cleaners.

C.
Health
effects
from
exposure
to
halogenated
solvents
Methylene
chloride,
perchloroethylene,
trichloroethylene,
and
1,1,1,­
trichlorothane
are
the
primary
halogenated
solvents
used
for
solvent
cleaning.
Although
production
of
1,1,1,­

trichlorothane
has
ceased
in
the
United
States,
a
declining
quantity
of
stockpiled
TCA
continues
to
be
used.
Carbon
tetrachloride
and
chloroform
are
no
longer
used
as
degreasing
solvents.

Therefore,
their
health
effects
are
not
of
a
concern
in
this
proposed
standard.

Methylene
chloride
is
predominantly
used
as
a
solvent.
The
acute
effects
of
methylene
chloride
inhalation
in
humans
consist
mainly
of
nervous
system
effects
including
decreased
13
visual,
auditory,
and
motor
functions,
but
these
effects
are
reversible
once
exposure
ceases.
The
effects
of
chronic
exposure
to
methylene
chloride
suggest
that
the
central
nervous
system
is
a
potential
target
in
humans
and
animals.
Human
data
are
inconclusive
regarding
methylene
chloride
and
cancer.
Animal
studies
have
shown
increases
in
liver
and
lung
cancer
and
benign
mammary
gland
tumors
following
the
inhalation
of
methylene
chloride.
EPA
has
classified
methylene
chloride
as
a
Group
B2,
probable
human
carcinogen.
EPA
is
currently
reassessing
its
potential
toxicity/
carcinogenicity.
All
activities
related
to
this
reassessment
are
expected
to
be
complete
by
July
2007.

Perchloroethylene
(
or
Tetrachloroethylene)
is
widely
used
for
dry­
cleaning
fabrics
and
metal
degreasing
operations.
The
main
health
effects
of
PCE
are
neurological,
liver,
and
kidney
damage
following
acute
(
short­
term)
and
chronic
(
long­
term)
inhalation
exposure.
Animal
studies
have
reported
an
increased
incidence
of
liver
cancer
in
mice
via
inhalation,
kidney
cancer,
and
mononuclear
cell
leukemia
in
rats.
PCE
was
considered
to
be
a
"
probable
carcinogen"
(
Group
B)
when
assessed
under
the
previous
1986
Guidelines
by
the
EPA
Science
Advisory
Board.
EPA
is
currently
reassessing
its
potential
carcinogenicity.
All
activities
related
to
this
reassessment
are
expected
to
be
complete
by
August,
2007.

The
acute
inhalation
exposure
effects
from
1,1,1­
trichloroethane
include
hypotension,

mild
hepatic
effects,
and
central
nervous
system
depression.
Cardiac
arrhythmia
and
respiratory
arrest
may
result
from
the
depression
of
the
central
nervous
system.
Symptoms
of
acute
inhalation
exposure
include
dizziness,
nausea,
vomiting,
diarrhea,
loss
of
consciousness,
and
decreased
blood
pressure
in
humans.
After
chronic
inhalation
exposure
to
1,1,1­
trichloroethane,

some
liver
damage
was
observed
in
mice
and
ventricular
arrhythmias
were
observed
in
humans.

EPA
has
classified
1,1,1­
trichloroethane
as
a
Group
D,
not
classifiable
as
to
human
carcinogenicity.
EPA
is
currently
reassessing
its
potential
toxicity
(
related
to
chronic
and
less
than­
lifetime
exposures).
All
activities
related
to
this
reassessment
are
expected
to
be
complete
by
September
2006.

Most
of
the
trichloroethylene
used
in
the
United
States
is
released
into
the
atmosphere
from
industrial
degreasing
operations.
Acute
and
chronic
inhalation
exposure
to
trichloroethylene
can
affect
the
human
central
nervous
system,
with
symptoms
such
as
dizziness,

headaches,
confusion,
euphoria,
facial
numbness,
and
weakness.
Liver,
kidney,
immunological,

endocrine,
and
developmental
effects
have
also
been
reported
in
humans.
A
recent
analysis
of
14
available
epidemiological
studies
reports
trichloroethylene
exposure
to
be
associated
with
several
types
of
cancers
in
humans,
especially
kidney,
liver,
cervix,
and
lymphatic
system.
Animal
studies
have
reported
increases
in
lung,
liver,
kidney,
and
testicular
tumors
and
lymphoma.
EPA
has
classified
trichloroethylene
as
a
Group
B2/
C,
an
intermediate
between
a
probable
and
possible
human
carcinogen.
EPA
is
currently
reassessing
the
cancer
classification
of
trichloroethylene.

II.
Summary
of
the
Proposed
Rule
Requirements
A.
Proposed
requirements
for
major
and
area
sources
Under
the
proposed
amendments,
the
requirements
for
all
new
and
existing,
major
and
area
sources
are
the
same.
The
proposed
revisions
would
require
each
facility
to
comply
with
a
facility­
wide
solvent
emissions
limit.
The
proposed
emissions
limits
are
40,000
kg/
yr
(
kilograms/
year)
MC­
equivalent
applied
facility­
wide
and
25,000
kg/
yr
MC­
equivalent
applied
facility­
wide.
The
facility­
wide
solvent
emissions
limit
requires
that
the
owner
or
operator
of
each
facility
ensure
that
the
combined
emissions
of
PCE,
TCE,
and
MC
from
all
of
the
solvent
cleaning
machines
at
the
facility
be
less
than
or
equal
to
the
solvent
emission
levels
specified
in
the
proposed
amendments
and
summarized
in
Table
2.
This
approach
gives
the
owner
or
operator
of
the
facility
the
flexibility
to
choose
any
means
of
reducing
the
facility­
wide
emissions
of
PCE,
TCE,
and
MC
to
complying
with
facility­
wide
emissions
limits.
The
proposed
amendments
are
in
addition
to
the
existing
NESHAP
requirements,
and
therefore,
all
requirements
of
the
existing
NESHAP
remain
in
place.

Table
2
shows
data
for
the
facility­
wide
emission
limits.
We
are
proposing
both
of
these
options
and
are
soliciting
comment
on
which
of
these
two
options
is
most
appropriate.
As
can
be
seen
in
Table
2,
each
halogenated
solvent
has
an
associated
facility­
wide
emission
limit.
These
limits
are
for
facilities
that
only
emit
that
halogenated
solvent.
If
more
than
one
halogenated
solvent
is
used,
the
owner
or
operator
of
the
facility
must
calculate
the
facility's
weighted
emissions
using
equation
1
and
comply
with
the
limit
in
the
last
row
of
Table
2.

Table
2.
 
Summary
of
the
Proposed
Facility­
Wide
Annual
Emission
Limits
Solvents
Emitted
Proposed
Facility­
Wide
Annual
Emission
Limits
in
kg(
lb)
­
Option
1
Proposed
Facility­
Wide
Annual
Emission
Limits
in
kg(
lb)
­
Option
2
PCE
only
2,083
(
4,593)
3,333
(
7,349)
TCE
only
6,250
(
13,779)
10,000
(
22,046)
15
MC
only
25,000
(
55,115)
40,000
(
88,183)
Multiple
solvents
 
Calculate
the
weighted
emissions
using
equation
1
25,000
(
55,115)
40,000
(
88,183)

Equation
1:
(
lbs
of
PCE
emissions
x
12)+(
lbs
of
TCE
emissions
x
4)
+
(
lbs
of
MC
emissions)
=
Weighted
Emissions
in
lbs
There
is
no
additional
equipment
monitoring
or
work
practice
requirements
associated
with
the
facility­
wide
annual
emissions
limit.
Compliance
with
the
emission
limit
is
demonstrated
by
determining
the
annual
PCE,
TCE,
and
MC
emissions
for
all
cleaning
machines
at
the
facility.
This
is
determined
based
on
records
of
the
amounts
and
dates
of
the
solvents
added
to
cleaning
machines
during
the
year,
the
amounts
and
dates
of
solvents
removed
from
cleaning
machines
during
the
year,
and
the
amounts
and
dates
of
the
solvents
removed
from
cleaning
machines
in
solid
waste.
Reporting
requirements
include
an
initial
notification
report,

an
initial
statement
of
compliance
report,
annual
compliance
reports,
and
an
exceedance
report
(
required
only
when
an
exceedance
occurs).

III.
Rationale
for
the
Proposed
Rule
A.
What
is
our
approach
for
developing
residual
risk
standards?

Following
our
initial
determination
that
the
individual
most
exposed
to
emissions
from
the
category
considered
exceeds
a
1­
in­
1
million
individual
cancer
risk,
our
approach
to
developing
residual
risk
standards
is
based
on
a
two­
step
determination
of
acceptable
risk
and
ample
margin
of
safety.
The
first
step,
consideration
of
acceptable
risk,
is
only
a
starting
point
for
the
analysis
that
determines
the
final
standards.
The
second
step
determines
an
ample
margin
of
safety,
which
is
the
level
at
which
the
standards
are
set.

B.
How
did
we
estimate
residual
risk?

Cancer
and
noncancer
health
impacts
caused
by
environmental
exposures
generally
cannot
be
isolated
and
measured
directly.
Even
if
it
were
possible
to
do
so,
we
would
not
be
able
to
use
measurements
to
assess
the
impacts
of
future
or
alternative
regulatory
control
strategies.

As
a
result,
modeling­
based
risk
assessment
is
used
as
a
tool
to
estimate
health
risks
for
many
16
EPA
programs.
In
risk
assessments,
there
are
many
possible
levels
of
analysis
from
the
most
basic
screening
approach
to
the
more
refined,
detailed
assessment.

C.
What
did
we
analyze
in
the
risk
assessment?

Three
sources
of
data
were
used
to
characterize
the
source
for
the
residual
risk
assessment,
EPA's
1999
NEI
database,
a
sample
of
MACT
compliance
reports
obtained
from
states
and
EPA
regions,
and
information
compiled
from
Clean
Air
Act
Title
V
permits.

Together,
these
sources
provided
data
for
2,672
unique
cleaning
machines
at
1,167
unique
facilities.
The
1,167
facilities
represent
approximately
61
percent
of
the
1,900
total
facilities
estimated
to
be
in
the
source
category.

The
majority
of
the
data,
approximately
90
percent,
were
obtained
from
the
1999
NEI
database.
The
NEI
data
provided
information
for
2,672
emission
points
at
1,093
facilities.
The
types
of
data
obtained
from
the
NEI
database
include
machine
type
(
from
SCC
codes
and
unit
descriptions),
HAP
emissions
data,
and
stack
characteristics.
The
compliance
reports
collected
for
the
residual
risk
assessment
provided
information
for
195
cleaning
machines
at
96
facilities.

The
types
of
data
obtained
from
the
compliance
report
include
machine
types,
machines
sizes,

solvent
consumption
rates,
HAP
emissions
data,
compliance
options,
and
control
equipment
choices.
We
gathered
machine­
specific
data
for
continuous
web
cleaning
machines
from
Title
V
permits
and
other
sources.
These
data,
which
included
74
cleaning
machines
at
seven
facilities,

were
added
to
the
cleaning
machine
data
obtained
from
compliance
reports.

Halogenated
solvent
cleaning
machines
are
co­
located
with
many
and
diverse
types
of
industries.
An
analysis
of
MACT
source
category
codes
in
the
1999
NEI
data
found
that
approximately
74
percent
of
the
1,093
halogenated
solvent
cleaning
sources
in
our
database
are
co­
located
with
at
least
one
other
source
category.
Approximately
80
percent
of
the
halogenated
solvent
emissions
from
solvent
cleaning
machines
occurred
at
facilities
where
other
source
categories
appeared
to
be
co­
located.
However,
the
risk
assessment
evaluated
the
emissions
coming
from
the
degreasing
operations
only
and
did
not
consider
emissions
of
HAPs
that
were
identified
for
co­
located,
non­
degreasing
operations.

The
residual
risk
assessment
used
HAP
emissions
data
from
the
assessment
database
described
above.
The
database
contains
a
mix
of
actual
and
allowable
post­
MACT
emission
17
rates.
These
data
were
used
to
estimate
the
baseline
residual
risks
and
to
evaluate
regulatory
options
developed
to
look
at
further
HAP
emission
reductions.

D.
How
we
assessed
environmental
impacts
Although
the
risk
assessment
focuses
on
estimating
potential
risks
to
humans,
we
are
also
required
to
consider
adverse
impacts
to
the
environment
as
a
part
of
a
residual
risk
assessment.

To
ensure
that
no
adverse
effects
to
wildlife
(
including
birds)
result
from
emissions
of
HAPs
from
this
source
category,
we
carried
out
an
assessment
of
ecological
effects
via
inhalation
toxicity.
Maximum
long­
term
air
concentrations
of
HAPs
at
the
most
exposed
census
block
centroid
were
used
as
the
exposure
concentrations,
and
estimated
exposure
concentrations,
and
estimated
exposure
concentrations
were
compared
to
conservative
ecological
toxicity
screening
values.

Because
none
of
the
source
category
HAPs
are
considered
to
be
persistent
and
bioaccumulative
compounds,
we
expect
risks
to
wildlife
via
ingestion
and
other
non­
inhalation
routes
and
risks
to
non­
terrestrial
animals
to
be
insignificant.
In
addition,
the
majority
(
over
99
percent)
of
the
mass
of
PCE,
TCE,
1,1,1,­
TCA,
and
MC
will
partition
preferentially
to
air
rather
than
water,
soil,
or
sediment,
providing
further
evidence
that
non­
inhalation
toxicity
to
ecological
receptors
is
of
little
concern.

E.
Results
of
the
risk
assessment
The
baseline
residual
risk
assessment
for
the
halogenated
solvent
cleaning
source
category
used
HAP
emissions
data
from
an
assessment
database
that
included
1,167
sources.

This
assessment
database
represents
approximately
61
percent
of
the
1,900
facilities
in
the
source
category.
Estimates
of
maximum
individual
cancer
risk
and
chronic
non­
cancer
HI
were
calculated
for
each
facility.
Results
presented
in
this
section
have
been
scaled­
up
proportionally
to
reflect
results
for
the
1,900
facilities
in
the
source
category.

Table
3
summarizes
the
estimated
lifetime
cancer
risk
results.
The
table
shows
the
number
of
persons
in
the
population
and
the
number
of
halogenated
solvent
cleaning
facilities
that
are
associated
with
various
levels
of
lifetime
cancer
risk.
The
highest
risk
to
an
individual
living
in
the
vicinity
of
one
of
the
halogenated
solvent
cleaning
facilities
(
the
maximum
individual
risk)
is
200
in­
a­
million.
For
the
population,
the
number
of
people
with
risks
greater
18
than
or
equal
to
one
in­
a­
million
is
approximately
5,900,000
people
with
86
of
these
exposed
to
risks
greater
or
equal
to
100
in­
a­
million.
These
risks
correspond
to
an
annual
cancer
incidence
of
0.4.

Table
3.
­
Population
Risk
Distribution
and
Number
of
Facilities
at
Various
Levels
of
Maximum
Risk
 
Baseline
(
Scaled
to
National
Level)
1
Estimated
Lifetime
Cancer
Risk
(
in­
a­
million)
National­
scale
Population2,3
Number
of
Facilities
in
the
Source
Category
at
the
Estimated
Risk
Level4
 
100
86
7
 
10
to
<
100
42,000
117
 
1
to
<
10
5,900,000
415
<
1
or
no
cancer
risk
(
i.
e.,
emit
non­
carcinogen
only)
­
1,3615
Total
5,942,086
1,900
1
Represents
the
estimated
numbers
of
people
residing
in
census
blocks
with
concentrations
associated
with
risks
at
the
designated
risk
level.
2
National­
scale
population
estimated
for
this
source
category
by
multiplying
the
populations
at
the
specified
cancer
risk
level
by
1,900/
1,167.
Population
counts
have
been
rounded.
3
These
population
numbers
reflect
adjustments
in
population
risk
due
to
residency
time
variations.
4
Estimated
by
multiplying
the
number
of
sources
at
the
specified
cancer
risk
level
(
in
Table
B­
1)
by
1,900/
1,167.
5
Calculated
as
671
(
sources
at
<
1
in­
a­
million
risk)
plus
690
(
sources
that
emit
1,1,1­
TCA
only).

We
also
evaluated
potential
risks
for
adverse
health
effects
other
than
cancer.
Calculated
chronic
non­
cancer
HIs
were
below
1
for
all
1,167
facilities
included
in
the
risk
assessment.
The
highest
HI
was
estimated
to
be
0.2.
Given
these
results,
it
is
expected
that
chronic
non­
cancer
HIs
would
be
below
1
for
all
1,900
facilities
in
the
source
category.

The
calculation
of
the
aggregate
non­
cancer
hazard
may
be
described
for
multiple
substances
in
terms
of
the
Target
Organ
Specific
Hazard
Index
(
TOSHI).
The
TOSHI
represents
the
sum
of
HQs
for
individual
air
toxics
that
affect
the
same
organ
or
organ
system.

An
ecological
screening
assessment
for
potential
terrestrial
receptors
was
conducted
to
determine
if
there
were
any
potentially
significant
ecological
effects
that
warranted
a
more
refined
level
of
analysis.
Maximum
long­
term
air
concentrations
of
HAPs
at
the
most
exposed
census
block
centroid
were
used
as
the
exposure
concentrations,
and
estimated
exposure
concentrations
were
compared
to
conservative
ecological
toxicity
screening
values.
Calculated
hazard
quotients
associated
with
terrestrial
ecological
receptors
were
well
below
1
for
all
HAPs
at
all
facilities.
Because
of
the
health­
protective
assumptions
used
in
this
assessment,
it
is
19
believed
that
the
ecological
screening
values
developed
would
also
be
protective
of
terrestrial
ecological
receptors
that
are
threatened
or
endangered.

F.
Regulatory
Scenarios
Six
scenarios
were
developed
to
evaluate
reductions
in
residual
risk
if
post­
MACT
emissions
were
controlled
further.
The
scenarios
are
not
based
on
specific
emission
control
technologies
or
practices,
but
represent
regulatory
options
that
require
capping
emissions
at
specific
levels.
As
mentioned
in
this
report,
these
scenarios
are
based
on
a
range
of
maximum
facility­
level
emissions
rates.
Emission
rates
for
the
scenarios
were
developed
from
baseline
emission
data
in
the
assessment
sample.
To
estimate
emissions
rates
for
a
scenario,
the
baseline
post­
MACT
emissions
rates
were
capped
by
scenario­
specific
maximum
annual
emission
rates.

By
comparing
the
results
across
the
scenarios,
the
relationship
between
risk
reductions
and
the
number
of
facilities
affected
may
be
evaluated.

For
Regulatory
Option
Scenario
1,
EPA
assumed
that
technologies
or
practices
implemented
for
further
post­
MACT
control
of
HAP
emissions
would
result
in
each
facility
emitting
no
more
than
100,000
kg/
yr
(
220,000
lbs/
yr)
of
MC­
equivalent
HAP.
Each
of
the
six
evaluated
regulatory
scenarios
are
summarized
below.

°
Regulatory
Option
Scenario
1
­­
Assumes
that
all
sources
would
reduce
MCequivalent
emissions
to
no
more
than
100,000
kg/
yr
(
220,000
lbs/
yr).

°
Regulatory
Option
Scenario
2
­­
Assumes
that
all
sources
would
reduce
MCequivalent
emissions
to
no
more
than
60,000
kg/
yr
(
132,000
lbs/
yr).

°
Regulatory
Option
Scenario
3
­­
Assumes
that
all
sources
would
reduce
MCequivalent
emissions
to
no
more
than
40,000
kg/
yr
(
88,000
lbs/
yr).

°
Regulatory
Option
Scenario
4
­­
Assumes
that
all
sources
would
reduce
MCequivalent
emissions
to
no
more
than
the
25,000
kg/
yr
(
55,000
lbs/
yr).

°
Regulatory
Option
Scenario
5
­­
Assumes
that
all
sources
would
reduce
MCequivalent
emissions
to
no
more
than
15,000
kg/
yr
(
33,000
lbs/
yr).

°
Regulatory
Option
Scenario
6
­­
Assumes
that
all
sources
would
reduce
MCequivalent
emissions
to
no
more
than
6,000
kg/
yr
(
13,200
lbs/
yr).

An
example
of
how
these
options
work
in
practice
is
the
following.
Under
control
option
20
5,
each
facility
must
limit
the
total
combined
emissions
of
PCE,
TCE,
and
MC
in
kg
to
60,000
kg
MC
equivalent.
So
for
a
facility
that
emits
4,000
kg
of
PCE,
2,000
kg
of
TCE,
and
10,000
kg
or
MC
the
MC
equivalent
emission
would
be
determined
as
follows:

MC
equivalent
emissions
in
kg
=
(
4,000
kg
emissions
of
PCE
x
12)
+
(
2,000
kg
of
TCE
x
4)
+
(
10,000
kg
of
MC)

=
48,000
kg
+
8,000
kg
+
10,000
kg
=
66,000
kg
Therefore,
this
facility
is
6,000
kg
MC
equivalent
over
the
limit
in
Regulatory
Option
Scenario
5.

To
comply
with
the
limit
the
facility
could
change
practices
or
apply
controls
to
do
the
following:

1.
Reduce
PCE
emissions
by
500
kg,

2.
Reduce
TCE
emissions
by
1,500
kg,

3.
Reduce
MC
emissions
by
6,000
kg,

4.
Or
any
combination
of
reducing
PCE,
TCE,
and
MC
emissions
where:

(
PCE
emissions
reduction
in
kg
x
12)
+
(
TCE
emissions
reduction
in
kg
x
4)
+
(
MC
emissions
reduction
in
kg)
=
6,000
kg
or
more
Establishing
the
control
options
on
a
facility­
wide
basis
allows
each
facility
the
flexibility
to
comply
in
the
most
cost
effective
manner.
This
is
because
each
facility
can
choose
which
units
to
control,
which
controls
to
apply,
and
which
solvents
to
control
so
long
as
the
limit
is
met.

G.
Impacts
for
Each
Option
Table
4
shows
that
the
decrease
in
maximum
individual
risk
ranges
from
75%
with
Regulatory
Option
1
(
i.
e.,
from
200
in­
a­
million
baseline
to
50
in­
a­
million)
to
99%
with
Option
6
(
i.
e.,
from
200
in­
a­
million
baseline
to
3
in­
a­
million).
The
corresponding
annual
incidence
estimates
decrease
over
the
range
from
35
percent
for
Option
1
to
90
percent
for
Option
6.

Likewise,
there
are
large
shifts
in
the
number
of
people
with
risks
greater
than
or
equal
to
one
in
21
a­
million
to
below
one
in­
a­
million.
The
reduction
in
population
with
risks
greater
than
or
equal
to
one
in­
a­
million
ranges
from
66%
for
Option
1
to
over
99
percent
for
Option
6.

Table
5
presents
the
number
of
facilities
at
estimated
cancer
risk
levels
for
the
regulatory
option
scenarios.
Baseline
results
are
provided
for
comparison.
Numbers
represent
national­
scale
estimates
(
i.
e.,
the
numbers
of
facilities
were
scaled
by
a
factor
of
approximately
1.6).

Table
4
­
Cancer
Risk
Results
 
Baseline
vs.
Regulatory
Option
Scenarios
(
Scaled
to
National
Level)
Baseline
Regulatory
Options
(
max
MC
equivalent
emissions
in
kg/
yr)
Cancer
Risk
Results
(
no
control)
Option
1
100,000
Option
2
60,000
Option
3
40,000
Option
4
25,000
Option
5
15,000
Option
6
6,000
Maximum
Individual
Risk
(
in­
amillion
200
50
30
20
10
8
3
Annual
Incidence
0.40
0.26
0.21
0.17
0.13
0.09
0.04
Estimated
Lifetime
Cancer
Risk
(
in­
a­
million)
Estimated
National
Population
1,2
 
1
to
<
10
5,900,000
2,000,000
1,200,000
630,000
200,000
200,000
8,200
 
10
to
<
100
42,000
5,100
1,400
700
67
0
0
 
100
86
0
0
0
0
0
0
Total
Population
at
 
1
5,942,086
2,005,100
1,201,400
630,700
200,067
200,000
8,200
Notes:
1.
National
population
estimated
for
this
source
category
by
multiplying
the
populations
at
the
specified
cancer
risk
level
by
1,900/
1,167.
Population
counts
for
the
individual
risk
bins
have
been
rounded
to
two
significant
figures.
2.
These
population
numbers
reflect
adjustments
in
population
risk
due
to
residency
time
variations.

Table
5
­
Number
of
Facilities
at
Various
Levels
of
Risk
 
Baseline
vs.
Regulatory
Option
Scenarios
(
Scaled
to
National
Level)
Number
of
Facilities
in
the
Source
Category
at
the
Estimated
Risk
Level
1
Baseline
Regulatory
Options
(
max
MC
equivalent
emissions
in
kg/
yr)
Estimated
Lifetime
Cancer
Risk
(
in­
amillion
(
no
control)
Option
1
100,000
Option
2
60,000
Option
3
40,000
Option
4
25,000
Option
5
15,000
Option
6
6,000
 
100
7
0
0
0
0
0
0
 
10
to
<
100
117
85
57
29
7
0
0
 
1
to
<
10
415
453
477
501
492
461
239
<
1
or
no
cancer
risk
(
i.
e.,
facilities
emit
noncarcinogen
1,361
1,362
1,366
1,369
1,402
1,439
1,660
22
only)
2
Notes:
1.
Estimated
by
multiplying
the
number
of
facilities
at
the
specified
cancer
risk
level
by
1,900/
1,167.
2.
Calculated
as
facilities
at
<
1
in­
a­
million
risk
plus
690
(
facilities
that
emit
1,1,1­
TCA
only).

We
acknowledge
that
there
are
uncertainties
in
various
aspects
of
risk
assessment
due
to
the
use
of
some
modeling
and
exposure
assumptions.
Specific
possible
uncertainties
in
the
risk
assessment
include:
the
size
of
the
source
category,
use
of
actual
versus
allowable
emissions,

lack
of
source
specific
data
on
peak
emissions,
and
modeling
uncertainties
(
e.
g.,
meteorology,

emission
point
locations,
release
parameters,
urban
versus
rural
dispersion,
population
size
and
exposure,
co­
location
issues,
and
dose
response
values).
Given
the
possible
impacts
of
the
assumptions
and
modeling
parameters
used
in
this
assessment,
it
is
reasonable
to
assume
that
overall,
this
assessment
is
not
likely
to
over­
or
underestimate
risks
preferentially
and
that
the
results
presented
are
a
reasonable,
best
estimate
of
risks
to
both
the
individual
maximally
exposed
and
the
population.

We
determined
that
a
risk­
based
emission
limit
on
the
highest
risk
sources
would
provide
an
opportunity
for
additional
control
that
would
be
achievable
and
reasonable.
We
believe
that
halogenated
solvent
cleaning
facilities,
subject
to
the
emission
limit,
can
achieve
the
proposed
limits
at
a
reasonable
cost
if
not
actually
incurring
a
cost
savings.
Both
co­
proposed
emission
limits
would
provide
an
ample
margin
of
safety
to
protect
public
health
and
the
environment.
II.
Costs
for
Individual
Controls
A
suite
of
controls
was
developed
that
achieve
emission
reductions
beyond
the
level
of
the
MACT
and
that
reduce
the
level
of
cancer
risk
associated
with
the
emissions
(
Table
6).
Two
of
the
controls
are
retrofit
controls
that
can
be
added
to
existing
cleaning
machines,
three
controls
are
solvent
switching
options
that
reduce
cancer
risk,
and
one
control
requires
the
replacement
of
existing
equipment
with
a
new
vacuum
to
vacuum
cleaning
machine.

Table
6
.
Emission
Controls
Beyond
the
MACT
Standard
and
Controls
That
Reduce
Cancer
Risk
And
Costs
for
Each
Control
Type
Description
%
Control
Total
Capital
Costs
Annualized
Capital
Costs
O&
M
Costs
Total
Annual
Emission
Control
Costs
(
a)
1.5
Freeboard
Ratio
(
1.0FBR),
Working
Mode
Cover
(
WC),
Freeboard
Refrigeration
Device
(
FRD)
0.5
$
25,645
$
2,821
$
2,015
$
4,836
Control
Equipment
Retrofits
1.5
Freeboard
Ratio
(
1.5FBR)
0.3
$
20,380
$
2,242
$
0
$
2,242
PCE
to
MC
0.93
$
15,677
$
1,725
$
928
$
2,653
PCE
to
TCE
0.77
$
0
$
0
($
2,022)
b
($
2,022)
Solvent
Switching
TCE
to
MC
0.7
$
15,677
$
1,725
$
2,950
$
4,675
Machine
Replacement
Vacuum
to
Vacuum
Cleaning
Machine
0.97
$
399,000
$
37,663
$
0
$
37,663
a
 
Does
not
include
cost
savings
due
to
reduced
solvent
purchases.
The
solvent
savings
were
calculated
for
each
specific
unit
based
on
the
volume
of
solvent
emissions
reduced
and
the
cost
of
the
specific
solvent
in
$/
gal.
b
 
Values
in
(
)
indicate
a
cost
savings.

The
costs
for
the
retrofit
controls
were
based
on
vendor
estimates
obtained
in
2005.
The
capital
costs
were
based
on
equipment
for
a
solvent
cleaning
machine
with
a
solvent­
air
interface
area
of
2.5
m2,
which
is
the
average
size
of
the
solvent
cleaning
machines
in
the
database
for
which
size
data
are
available.
The
annualized
capital
costs
were
based
on
a
15
year
equipment
lifetime
and
a
7%
interest
rate.
A
50%
emission
reduction
is
expected
to
result
from
the
addition
of
the
1.0FBR,
WC,
and
FRD
control
combination.
A
30%
emission
reduction
is
expected
to
result
from
the
addition
of
a
1.5FBR.
These
percent
emission
reductions
were
calculated
using
percent
reduction
values
and
procedures
that
were
developed
for
the
NESHAP.

The
development
of
the
costs
for
the
solvent
switching
options
included
considerations
of
24
changes
in
the
cost
of
the
solvent,
changes
in
solvent
consumption
rates,
changes
in
energy
requirements,
costs
for
equipment
modifications,
and
changes
in
productivity.
Capital
costs
were
scaled
to
2004
dollars
and
were
annualized
assuming
a
15­
year
equipment
lifetime
and
a
7%
interest
rate.
The
solvent
switching
scenarios,
their
costs,
and
impacts
are
fully
discussed
in
a
separate
memorandum
titled
"
Evaluation
of
the
Feasibility,
Costs,
and
Impacts
of
Switching
from
a
Halogenated
Solvent
with
a
High
Cancer
Unit
Risk
Value
to
a
Halogenated
Solvent
with
a
Lower
Cancer
Unit
Risk
Value."

Costs
for
the
vacuum­
to­
vacuum
cleaning
machines
are
based
on
vendor
estimates
obtained
in
2005.
The
vacuum­
to­
vacuum
cleaning
machine
capital
costs
were
based
on
the
replacement
of
a
solvent
cleaning
machine
with
a
solvent­
air
interface
area
of
2.5
m2,
which
is
the
average
size
of
the
solvent
cleaning
machines
in
the
database
for
which
size
data
are
available.

Capital
costs
were
annualized
based
on
a
20
year
equipment
lifetime
and
a
7%
interest
rate.
The
20­
year
equipment
lifetime
was
determined
based
on
information
from
equipment
manufacturers.
It
was
determined
that
a
97%
reduction
in
emissions
would
result
from
switching
from
an
existing
solvent
cleaning
machine
to
a
vacuum­
to­
vacuum
cleaning
machine.
The
emission
reduction
estimate
was
based
on
case
study
results
as
reported
in
"
Pollution
Prevention
Technology
Profile
Closed
Loop
Vapor
Degreasing"
by
the
Northeast
Waste
Management
Officials'
Association
(
NEWMOA)
dated
December
28,
2001.
In
the
study,
two
cleaning
machines
saw
a
reduction
in
solvent
use
of
97%,
a
third
saw
a
reduction
in
solvent
use
of
83%.

The
third
machine
had
a
smaller
reduction
in
solvent
use
due
to
the
heavy
soils
cleaned
by
the
machine.
Therefore,
more
solvent
was
being
lost
to
the
solid
waste
stream.

III.
Number
of
Affected
Solvent
Cleaners
Per
Regulatory
Option
This
section
presents
the
number
of
solvent
cleaners
affected,
and
the
costs
and
emission
reductions
expected
for
each
option.
Both
capital
and
annualized
costs
are
estimated.
First,
we
show
the
number
of
affected
solvent
cleaners
in
Table
7.
TABLE
7:
NUMBER
OF
SOLVENT
CLEANERS
SUBJECT
TO
CONTROL
AND
NOT
SUBJECT
TO
CONTROL
FOR
EACH
OF
THE
SIX
COMPLIANCE
OPTIONS
Group
of
Solvent
Cleaners
100,000
Kg
MC
#
%
of
Grand
Total
60,000
Kg
MC
40,000
Kg
MC
25,000
Kg
MC
15,000
Kg
MC
6,000
Kg
MC
Total
for
Solvent
Cleaners
in
NEI
Subject
to
Control
to
Meet
Residual
Risk
Option
153
9
251
15
378
23
486
29
621
37
852
51
Total
for
Solvent
Cleaners
in
NEI
Not
Subject
to
Control
to
Meet
Residual
Risk
Option
1504
91
1407
85
1280
77
1172
71
1037
63
805
49
Grand
Total
of
Solvent
Cleaners
in
NEI
1658
100
1658
100
1658
100
1658
100
1658
100
1658
100
26
TABLE
8:
NUMBER
OF
UNITS
ASSIGNED
TO
EACH
CONTROL
OPTION
FOR
EACH
OF
THE
SIX
COMPLIANCE
OPTIONS
Control
Option
100,000
kg
MC
#
%
of
Total
Controlled
60,000
kg
MC
#
%
of
Total
Controlled
40,000
kg
MC
#
%
of
Total
Controlled
25,000
kg
MC
#
%
of
Total
Controlled
15,000
kg
MC
#
%
of
Total
Controlled
6,000
kg
MC
#
%
of
Total
Controlled
Vacuum
51
33
73
29
116
31
187
39
289
46
468
55
PCE
to
MC
8
5
16
6
24
6
28
6
33
5
41
5
PCE
to
TCE
24
16
26
10
26
7
47
10
60
10
64
7
TCE
to
MC
29
19
54
21
65
17
72
15
77
12
117
14
Retro
 
1.5
FBR,
WC,
FRD
23
15
23
9
73
19
73
15
103
17
77
9
Retro
 
1.5
FBR
18
12
59
23
73
19
78
16
60
10
86
10
Total
for
Units
in
NEI
Subject
to
Residual
Risk
Standard
153
100
251
100
378
100
486
100
621
100
852
100
Cost
and
Emission
Reductions
by
Regulatory
Option
The
costs
and
emission
reductions
for
all
units
at
all
facilities
with
emissions
above
the
control
option
limits
were
totaled
to
yield
the
total
national
costs
and
emission
reductions.
Table
9
shows
that
half
of
the
units
using
TCE,
PCE,
or
MC
are
subject
to
control
beyond
MACT
at
the
6,000
kg
MC
equivalent
option.
About
9%
of
the
units
using
TCE,
PCE,
or
MC
are
subject
to
control
beyond
MACT
at
the
100,000
kg
MC
equivalent
option.
The
lower
the
limit
is
established,
the
greater
the
number
of
units
that
must
be
controlled
to
achieve
the
limit.

Emission
reductions
are
greater
the
lower
the
limit
is
established,
therefore,
the
solvent
savings
are
greater.

Table
10
shows
the
HAP
emission
reductions
by
each
regulatory
option.
Emission
reductions
range
from
4,031
tons
per
year
for
the
100,000
kg
MC
equivalent
option
to
8,595
tons
per
year
for
the
6,000
kg
MC
equivalent
option.
At
the
100,000
option
emissions
of
PCE,
TCE
and
MC
are
reduced
by
41%.
At
the
6,000
option
emissions
of
PCE,
TCE
and
MC
are
reduced
by
87%.

Tables
11­
16
provide
the
costs
for
each
regulatory
option
broken
down
by
capital
and
annual
components
and
including
estimates
of
the
cost
savings
from
solvent
recovery.
Table
17
provides
a
summary
of
these
costs
as
well
as
emission
reductions
for
each
option.
Total
annual
emission
control
costs
range
from
a
savings
of
$
6
million/
year
for
the
40,000
kg
and
the
60,000
kg
MC
equivalent
control
options
to
a
cost
of
$
2
million/
year
for
the
6,000
kg
MC
control
option.
Capital
costs
for
the
six
control
options
range
from
approximately
$
22
million
for
the
100,000
kg
MC
equivalent
option
to
$
193
million
for
the
6,000
kg
MC
equivalent
option.

Annualized
capital
costs
range
from
$
2
million/
year
for
the
100,000
kg
MC
equivalent
option
to
$
18
million/
year
for
the
6,000
kg
MC
equivalent
option.
Operating
and
maintenance
costs
are
a
small
portion
of
the
overall
costs,
ranging
from
$
90K
for
the
100,000
kg
MC
equivalent
option
to
$
410K
for
the
6,000
kg
MC
equivalent
option.
Solvent
savings
have
a
significant
impact
on
total
annual
costs,
ranging
from
a
savings
of
over
$
16
million/
year
for
the
6,000
kg
MC
option
to
a
savings
of
over
$
7
million/
year
for
the
100,000
kg
MC
equivalent
option.
Solvent
savings
represent
the
cost
savings
that
result
from
reduced
solvent
purchases.

Incremental
costs
are
negative
for
the
100,000
kg
and
the
60,000
kg
MC
equivalent
options
at
($
1,292)/
ton
and
($
826)/
ton,
respectively.
Incremental
costs
for
the
remaining
four
options
are
positive
and
range
from
$
16/
ton
for
the
40,000
kg
MC
equivalent
option
to
28
$
5,554/
ton
for
the
6,000
kg
MC
equivalent
option.
TABLE
9:
EMISSION
REDUCTIONS
IN
TONS
BY
CONTROL
OPTION
FOR
EACH
OF
THE
SIX
COMPLIANCE
OPTIONS
Control
Option
100,000
kg
MC
Tons
%
60,000
kg
MC
Tons
%
40,000
kg
MC
Tons
%
25,000
kg
MC
Tons
%
15,000
kg
MC
Tons
%
6,000
kg
MC
Tons
%

Vacuum
1,843
77
2,322
77
2,907
80
3,401
82
4,054
86
4,663
88
PCE
to
MC
225
9
225
7
268
7
285
7
282
6
296
6
PCE
to
TCE
52
2
22
1
3
0
47
1
8
0
9
0
TCE
to
MC
35
1
159
5
91
3
131
3
118
3
181
3
Retro
 
1.5
FBR,

WC,
FRD
238
10
125
4
238
7
174
4
190
4
69
1
Retro
 
1.5
FBR
85
3
155
5
123
3
124
3
56
1
54
1
Total
Emission
Reductions
2,477
100
3,009
100
3,630
100
4,161
100
4,709
100
5,272
100
Total
Percent
Reduction
41
50
60
69
78
87
30
TABLE
10:
EMISSION
REDUCTIONS
IN
TONS
BY
HAP
FOR
EACH
OF
THE
SIX
COMPLIANCE
OPTIONS
HAP
100,000
kg
MC
60,000
kg
MC
40,000
kg
MC
25,000
kg
MC
15,000
kg
MC
6,000
kg
MC
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%

MC
439
18
453
15
524
14
602
14
699
15
849
16
TCE
1053
43
1,470
49
1,931
53
2,316
56
2,720
58
3,091
59
PCE
984
40
1,086
36
1,174
32
1,243
30
1,290
27
1,332
25
Total
2,477
100
3,009
100
3,629
100
4,161
100
4,709
100
5,272
100
Table
11.
Costs
by
Regulatory
Option
Scenario
 
100,000
kg
MC
Limit
Control
Option
Total
Capital
Costs
Annualized
Capital
Costs
O&
M
Costs
Solvent
Savings
Total
Annualized
Control
Costs
Vacuum
$
20,161,470
$
1,903,100
$
0
($
5,433,333)
($
3,530,233)

PCE
to
MC
$
127,768
$
14,059
$
7,563
($
481,481)
($
459,859)

PCE
to
TCE
$
0
$
0
($
49,438)
($
263,129)
($
312,567)

TCE
to
MC
$
459,963
$
50,612
$
86,553
($
119,508)
$
17,656
Retro
 
1.5
FBR,
WC,

FRD
$
585,222
$
64,375
$
45,977
($
796,033)
($
685,682)
31
Retro
 
1.5
FBR
$
365,413
$
40,195
$
0
($
278,448)
($
238,253)

Total
Costs
$
21,699,836
$
2,072,341
$
90,655
($
7,371,932)
($
5,208,937)

Table
12.
Costs
by
Regulatory
Option
Scenario
 
60,000
kg
MC
Emissions
Limit
Control
Option
Total
Capital
Costs
Annualized
Capital
Costs
O&
M
Costs
Solvent
Savings
Total
Annualized
Control
Costs
Vacuum
$
28,616,280
$
2,701,175
$
0
($
7,005,153)
($
4,303,979)

PCE
to
MC
$
255,535
$
28,118
$
15,126
($
489,844)
($
446,600)

PCE
to
TCE
$
0
$
0
($
52,734)
($
187,632)
($
240,366)

TCE
to
MC
$
843,266
$
92,788
$
158,681
($
547,817)
($
296,349)

Retro
 
1.5
FBR,

WC,
FRD
$
585,222
$
64,375
$
45,977
($
388,591)
($
278,240)

Retro
 
1.5
FBR
$
1,195,898
$
131,549
$
0
($
495,219)
($
363,670)

Total
Costs
$
31,496,202
$
3,018,003
$
167,050
($
9,114,256)
($
5,929,203)
32
Table
13.
Costs
by
Regulatory
Option
Scenario
 
40,000
kg
MC
Emissions
Limit
Control
Option
Total
Capital
Costs
Annualized
Capital
Costs
O&
M
Costs
Solvent
Savings
Total
Annualized
Control
Costs
Vacuum
$
46,176,270
$
4,358,714
$
0
($
8,930,369)
($
4,571,655)

PCE
to
MC
$
383,303
$
42,176
$
22,690
($
588,814)
($
523,948)

PCE
to
TCE
$
0
$
0
($
52,734)
($
112,536)
($
165,269)

TCE
to
MC
$
1,022,140
$
112,470
$
192,340
($
317,482)
($
12,672)

Retro
 
1.5
FBR,

WC,
FRD
$
1,881,072
$
206,918
$
147,782
($
747,995)
($
393,295)

Retro
 
1.5
FBR
$
1,494,873
$
164,436
$
0
($
410,267)
($
245,831)

Total
Costs
$
50,957,658
$
4,884,714
$
310,078
($
11,107,463)
($
5,912,671)

Table
14.
Costs
for
Regulatory
Option
Scenario
 
25,000
kg
MC
Emissions
Limit
Control
Option
Total
Capital
Costs
Annualized
Capital
Costs
O&
M
Costs
Solvent
Savings
Total
Annualized
Control
Costs
Vacuum
$
74,792,550
$
7,059,888
$
0
($
10,551,077)
($
3,491,189)

PCE
to
MC
$
434,410
$
47,800
$
25,715
($
632,344)
($
558,830)

PCE
to
TCE
$
0
$
0
($
95,580)
($
217,536)
($
313,116)

TCE
to
MC
$
1,124,354
$
123,717
$
211,574
($
451,594)
($
116,303)

Retro
 
1.5
FBR,
$
1,881,072
$
206,918
$
147,782
($
563,841)
($
209,141)
33
WC,
FRD
Retro
 
1.5
FBR
$
1,594,531
$
175,398
$
0
($
397,072)
($
221,674)

Total
Costs
$
79,826,917
$
7,613,721
$
289,491
($
12,813,464)
($
4,910,252)

Table
15.
Costs
by
Regulatory
Option
Scenario­
15,000
kg
MC
Emissions
Limit
Control
Option
Total
Capital
Costs
Annualized
Capital
Costs
O&
M
Costs
Solvent
Savings
Total
Annualized
Control
Costs
Vacuum
$
115,115,490
$
10,866,089
$
0
($
12,633,199)
($
1,767,110)

PCE
to
MC
$
511,070
$
56,235
$
30,253
($
640,937)
($
554,449)

PCE
to
TCE
$
0
$
0
($
121,947)
($
114,124)
($
236,070)

TCE
to
MC
$
1,201,015
$
132,152
$
226,000
($
408,980)
($
50,828)

Retro
 
1.5
FBR,

WC,
FRD
$
2,633,500
$
289,685
$
206,895
($
608,895)
($
112,315)

Retro
 
1.5
FBR
$
1,229,118
$
135,203
$
0
($
174,430)
($
39,227)

Total
Costs
$
120,690,193
$
11,479,364
$
341,200
($
14,580,565)
($
2,760,000)
34
Table
16.
Costs
by
Regulatory
Option
Scenario
­
6,000
kg
MC
Emissions
Limit
Control
Option
Total
Capital
Costs
Annualized
Capital
Costs
O&
M
Costs
Solvent
Savings
Total
Annualized
Control
Costs
Vacuum
$
186,656,190
$
17,619,025
$
0
($
14,578,221)
$
3,040,804
PCE
to
MC
$
638,838
$
70,294
$
37,816
($
677,961)
($
569,851)

PCE
to
TCE
$
0
$
0
($
128,539)
($
101,923)
($
230,461)

TCE
to
MC
$
1,839,853
$
202,446
$
346,212
($
624,155)
($
75,497)

Retro
 
1.5
FBR,

WC,
FRD
$
1,964,675
$
216,115
$
154,350
($
220,303)
$
150,161
Retro
 
1.5
FBR
$
1,760,628
$
193,669
$
0
($
156,172)
$
37,498
Total
Costs
$
192,860,184
$
18,301,548
$
409,839
($
16,358,735)
$
2,352,653
35
Table
17.
Summary
Table
of
Costs
and
Emission
Reductions
by
Regulatory
Option
Scenario
Compliance
Option
Total
Capital
Costs
Annualized
Capital
Costs
O&
M
Costs
Solvent
Savings
Total
Annualized
Control
Costs
Emissions
Reductions
(
Tons)

100,000
kg
MC
$
21,699,836
$
2,072,341
$
90,655
($
7,371,932)
($
5,208,937)
4,031
60,000
kg
MC
$
31,496,202
$
3,018,003
$
167,050
($
9,114,256)
($
5,929,203)
4,903
40,000
kg
MC
$
50,957,658
$
4,884,714
$
310,078
($
11,107,463)
($
5,912,671)
5,911
25,000
kg
MC
$
79,826,917
$
7,613,721
$
289,491
($
12,813,464)
($
4,910,252)
6,778
15,000
kg
MC
$
120,690,193
$
11,479,364
$
341,200
($
14,580,565)
($
2,760,000)
7,675
6,000
kg
MC
$
192,860,184
$
18,301,548
$
409,839
($
16,358,735)
$
2,352,653
8,595
III.
Economic
Impact
and
Small
Business
Analysis
The
residual
risk
standards
being
proposed
to
control
halogenated
solvents
will
potentially
affect
the
economic
welfare
of
owners
of
the
facilities
using
these
hazardous
air
pollutants.
The
ownership
of
these
facilities
ultimately
falls
on
private
individuals
who
may
be
owner/
operators
that
directly
conduct
the
business
of
the
firm
(
i.
e.,
"
mom
and
pop
shops"
or
partnerships)
or,
more
commonly,
investors
or
stockholders
that
employ
others
to
conduct
the
business
of
the
firm
on
their
behalf
(
i.
e.,
privately­
held
or
publicly­
traded
corporations).
The
individuals
or
agents
that
manage
these
facilities
have
the
capacity
to
conduct
business
transactions
and
make
business
decisions
that
affect
the
facility.
The
legal
and
financial
responsibility
for
compliance
with
a
regulatory
action
ultimately
rests
with
these
agents;
however
the
owners
must
bear
the
financial
consequences
of
the
decisions.
Environmental
regulations
like
this
rule
potentially
affect
all
businesses,
large
and
small,
but
small
businesses
may
have
special
problems
in
complying
with
such
regulations.

The
Regulatory
Flexibility
Act
(
RFA)
generally
requires
an
agency
to
prepare
a
regulatory
flexibility
analysis
of
any
rule
subject
to
notice
and
comment
rulemaking
requirements
under
the
Administrative
Procedure
Act
or
any
other
statute
unless
the
agency
certifies
that
the
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
Small
entities
include
small
businesses,
small
organizations,
and
small
governmental
jurisdictions.
This
analysis
identified
the
businesses
that
will
be
affected
by
this
proposed
rule
and
provides
an
analysis
to
assist
in
determining
whether
this
rule
is
likely
to
impose
a
significant
economic
impact
on
a
substantial
number
of
small
businesses.
The
screening
analysis
employed
here
is
a
"
sales
test"
that
computes
the
annualized
compliance
costs
as
a
share
of
sales
for
each
company.

A.
Identifying
and
Characterizing
Small
Entities
For
purposes
of
assessing
the
impacts
of
today's
rule
on
small
entities,
small
entity
is
defined
as:
(
1)
a
small
as
defined
by
the
Small
Business
Administration's
(
SBA)
regulations
at
13
CFR
121.201;"
(
2)
a
small
governmental
jurisdiction
that
is
a
government
of
a
city,
county,

town,
school
district
or
special
district
with
a
population
of
less
than
50,000;
and
(
3)
a
small
organization
that
is
any
not­
for­
profit
enterprise
which
is
independently
owned
and
operated
and
is
not
dominant
in
its
field.
37
The
companies
owning
the
facilities
using
halogenated
solvents
can
be
grouped
into
small
and
large
categories
using
Small
Business
Administration
(
SBA)
general
size
standard
definitions.
Size
standards
are
based
on
industry
classification
codes
(
i.
e.,
NAICS)
that
each
company
uses
to
identify
the
industry
or
industries
in
which
they
operate
in.
The
SBA
defines
a
small
business
in
terms
of
the
maximum
employment,
annual
sales,
or
annual
energy­
generating
capacity
(
for
EGUs)
of
the
owning
entity.
These
thresholds
vary
by
industry
and
are
evaluated
based
on
the
primary
industry
classification
of
the
affected
companies.
In
cases
where
companies
are
classified
by
multiple
NAICS
codes,
the
most
conservative
SBA
definition
was
used.

As
mentioned
earlier
in
this
report,
facilities
across
several
industries
use
halogenated
solvents
to
degrease
their
products,
therefore
a
number
of
size
standards
are
utilized
in
this
analysis.
For
the
industries
represented
in
this
analysis,
the
employment
size
standard
varies
from
500
to
1,500
employees.
The
annual
sales
standard
is
as
low
as
4
million
dollars
and
as
high
as
150
million
dollars.

B.
Screening­
Level
Analysis
For
the
purposes
of
assessing
the
potential
impact
of
this
rule
on
affected
businesses,
the
Agency
considers
the
costs
of
specific
compliance
options
considered.
The
share
of
the
facility's
annual
compliance
cost
relative
to
baseline
sales
for
each
facility­
owning
company
is
calculated
and
this
measure
is
used
to
determine
the
economic
impact
of
these
options
on
small
businesses.

When
a
company
owns
more
than
one
facility
that
potentially
faces
the
costs
of
complying
with
this
standard,
the
costs
for
each
facility
it
owns
are
summed
to
develop
the
numerator
of
the
test
ratio.
For
this
screening­
level
analysis,
annual
compliance
costs
are
defined
as
the
engineering
control
costs
incurred
by
these
companies;
thus,
they
do
not
reflect
the
changes
in
production
expected
to
occur
in
response
to
the
imposition
of
these
costs
and
the
resulting
market
adjustments.

EPA
determined
that
360
companies,
the
Federal
government,
and
the
government
of
the
District
of
Columbia
own
the
400
facilities
that
EPA
identified
as
using
halogenated
solvents.

The
Federal
government
operates
nine
of
these
facilities
while
the
District
of
Columbia
operates
one.
Neither
of
these
governmental
jurisdictions
are
considered
small
entities.
Employment
and
sales
data
were
available
for
281
of
the
companies
(
78
percent)
and
this
information
was
used
to
38
classify
the
firms
as
small
or
large
by
SBA
size
standards.
The
small
business
analysis
focuses
on
this
subset
of
the
companies
owning
facilities
that
use
halogenated
solvents.
Of
the
281
companies
included
in
the
analysis,
181
(
approximately
64
percent)
are
considered
small.

Tables
18­
23
report
the
summary
statistics
for
the
cost­
to­
sales
ratios
(
CSRs)
for
small
and
large
companies
in
this
analysis.
Table
20
contains
the
impacts
for
the
40,000
kg/
yr
MCequivalent
regulatory
option
scenario
and
Table
21
contains
the
impacts
for
the
25,000
kg/
yr
MC­
equivalent
regulatory
option
scenario;
these
are
the
options
co­
proposed
in
this
regulatory
action.
The
compliance
costs
estimated
for
these
companies
are
also
provided.
Note
that
this
small
business
analysis
includes
only
those
companies
for
which
data
could
be
located.

Therefore,
the
total
annual
compliance
cost
for
these
firms
does
not
equal
the
total
annual
compliance
cost
estimated
for
the
rule.
Under
the
proposed
options,
there
are
no
significant
impacts
anticipated
for
the
small
companies.
The
firms
in
this
analysis
with
cost­
to­
sales
ratios
that
exceed
three
percent
do
not
tend
to
face
higher
annual
compliance
costs,
but
rather
earn
lower
annual
revenue
than
the
other
small
businesses.
These
impacts
for
the
proposed
options,

Regulatory
Option
Scenarios
3
and
4,
range
from
only
5
firms
(
4
small)
out
of
281
(
186
small)

having
some
positive
cost
to
sales
estimate
for
the
least
stringent
option
(
known
as
Regulatory
Option
Scenario
1)
to
146
firms
(
124
small)
that
have
some
positive
cost
to
sales
estimate,
with
8
small
firms
out
of
these
124
having
annualized
compliance
costs
of
greater
than
3
percent
of
sales.
For
the
proposed
options,
the
impacts
range
from
9
firms
(
6
small)
that
have
some
positive
cost
to
sales
estimate
to
38
firms
(
32
small)
that
have
a
positive
cost
to
sales
estimate.
Only
one
small
business
affected
by
the
proposed
options
in
this
analysis
has
a
CSR
greater
than
three
percent
and
only
three
have
a
CSR
above
one
percent.
Finally,
Table
24
provides
a
summary
of
the
economic
impacts
to
affected
businesses
across
the
six
options.

C.
Excluded
Companies
Annual
sales
and
employment
data
could
not
be
located
for
91of
the
360
companies
that
use
halogenated
solvents
and,
as
mentioned
above,
have
been
excluded
from
the
analysis.

Without
these
data,
a
size
determination
cannot
be
made
for
these
companies
nor
could
CSRs
be
calculated.
Since
it
is
more
difficult
to
locate
company
data
for
small
companies,
it
is
possible
that
these
companies
are
small.
However,
without
sales
and
employment
data,
this
cannot
be
determined
with
certainty.
It
is
possible
that
these
companies
might
be
considered
large,
39
depending
on
the
SBA
size
standard
definition
for
their
NAICS
codes.
It
is
important
to
note
that
31
of
the
excluded
companies
are
expected
to
experience
cost
savings
as
a
result
of
this
control
option.

EPA
has
determined
that
the
average
cost
facing
excluded
companies
is
approximately
$
454
per
company.
This
average
cost
is
much
closer
to
zero
than
either
the
average
costs
facing
the
small
companies
($
9,200)
or
the
average
cost
savings
experienced
by
the
larger
companies
(
savings
of
$
2,300).
Additionally,
the
maximum
annual
compliance
costs
faced
by
the
excluded
companies
is
approximately
$
41,000
while
the
maximum
for
the
small
companies
is
$
77,000.

For
large
companies,
the
maximum
cost
is
$
179,000.
Given
this
information,
it
is
possible
that
these
excluded
facilities
would
not
be
affected
any
worse
than
the
small
companies
included
in
this
analysis.
Table
18.
Summary
Results
for
Small
Business
Analysis
for
Halogenated
Solvents
Residual
Risk
­
Regulatory
Option
Scenario
1
(
100,000
kg/
yr
MC)

Small
Large
All
Companies*

Total
Number
of
Companies
in
Analysis
186
95
281
Estimated
Annual
Compliance
Cost
Savings
(
2004$)
­$
891,780
­$
1,482,173
­$
2,373,953
Number
Share
Number
Share
Number
Share
Companies
in
Analysis
186
100%
95
100%
281
100%

Compliance
costs
are
0%
of
sales
or
negative
182
98%
94
98%
276
86%

Compliance
costs
are
>
0
to
1%
of
sales
4
2%
1
2%
5
13%

Compliance
costs
are
>
1
to
3%
of
sales
0
0%
0
0%
0
1%

Compliance
costs
are
>
3%
of
sales
0
0%
0
0%
0
0%

Compliance
Cost­
to­
Sales
Ratios
Average
0.00%**
0.00%
0.01%

Median
0.00%
0.00%
0.01%

Minimum
­
0.71%
­
0.01%
­
0.71%

Maximum
0.41%
0.01%
0.41%

*
includes
those
companies
for
which
sales
and
employment
data
could
be
located
**
the
value
0.00%
denotes
impacts
that
are
0.005%
and
below
Table
19.
Summary
Statistics
for
Small
Business
Analysis
for
Halogenated
Solvents
Residual
Risk
Regulatory
Option
Scenario
2
(
60,000
kg/
yr
MC)

Small
Large
All
Companies*

Total
Number
of
Companies
in
Analysis
181
98
279
Estimated
Annual
Compliance
Cost
Savings
(
2004$)
­$
696,465
­$
2,065,490
­$
2,761,955
Number
Share
Number
Share
Number
Share
Companies
in
Analysis
181
100%
98
100%
279
100%

Compliance
costs
are
0%
of
sales
or
negative
178
98%
96
98%
274
98%

Compliance
costs
are
>
0
to
1%
of
sales
3
2%
2
2%
5
2%

Compliance
costs
are
>
1
to
3%
of
sales
0
0%
0
0%
0
0%

Compliance
costs
are
>
3%
of
sales
0
0%
0
0%
0
0%

Compliance
Cost­
to­
Sales
Ratios
Average
­
0.04%
­
0.01%
­
0.03%

Median
0.00%**
0.00%
0.00%

Minimum
­
1.9%
­
1.14%
­
1.9%

Maximum
0.41%
0.01%
0.41%

*
includes
those
companies
for
which
sales
and
employment
data
could
be
located
**
the
value
0.00%
denotes
impacts
that
are
0.005%
and
below
42
Table
20.
Summary
Results
for
Small
Business
Analysis
for
Halogenated
Solvents
Residual
Risk
 
Regulatory
Option
Scenario
3
(
40,000
kg/
yr
MC)*

Small
Large
All
Companies**

Total
Number
of
Companies
in
Analysis
179
98
281
Estimated
Annual
Compliance
Cost
Savings
(
2004$)
­$
1,055,557
­$
1,648,782
­$
2,704,339
Number
Share
Number
Share
Number
Share
Companies
in
Analysis
179
100%
98
100%
277
100%

Compliance
costs
are
0%
of
sales
or
negative
173
97%
95
97%
268
97%

Compliance
costs
are
>
0
to
1%
of
sales
6
3%
3
3%
9
3%

Compliance
costs
are
>
1
to
3%
of
sales
0
0%
0
0%
0
1%

Compliance
costs
are
>
3%
of
sales
0
0%
0
0%
0
0%

Compliance
Cost­
to­
Sales
Ratios
Average
0.03%
0.01%
0.02%

Median
0.02%
0.01%
0.01%

Minimum
­
0.28%
0.01%
­
0.28%

Maximum
0.41%
0.02%
0.41%

*
This
is
Option
2
of
the
two
proposed
options.

**
includes
those
companies
for
which
sales
and
employment
data
could
be
located
43
Table
21.
Summary
Results
for
Small
Business
Analysis
for
Halogenated
Solvents
Residual
Risk
­
Regulatory
Option
Scenario
4
(
25,000
kg/
yr
MC)*

Small
Large
All
Companies**

Total
Number
of
Companies
in
Analysis
186
95
281
Estimated
Annual
Compliance
Cost
Savings
(
2004$)
­$
846,538
­$
1,459,953
­$
2,306,491
Number
Share
Number
Share
Number
Share
Companies
in
Analysis
186
100%
95
100%
281
100%

Compliance
costs
are
0%
of
sales
or
negative
154
82%
89
94%
243
86%

Compliance
costs
are
>
0
to
1%
of
sales
29
16%
6
6%
35
13%

Compliance
costs
are
>
1
to
3%
of
sales
2
1%
0
0%
2
1%

Compliance
costs
are
>
3%
of
sales
1
0%
0
0%
1
0%

Compliance
Cost­
to­
Sales
Ratios
Average
0.05%
­
0.01%
0.01%

Median
0.03%
0.01%
0.01%

Minimum
­
1.33%
­
0.01%
­
1.33%

Maximum
7.81%
0.01%
7.81%

*
This
is
Option
1
of
the
two
proposed
options.

**
includes
those
companies
for
which
sales
and
employment
data
could
be
located
44
Table
22.
Summary
Results
for
Small
Business
Analysis
for
Halogenated
Solvents
Residual
Risk
­
Regulatory
Option
Scenario
5
(
15,000
kg/
yr
MC)

Small
Large
All
Companies*

Total
Number
of
Companies
in
Analysis
181
99
280
Estimated
Annual
Compliance
Costs
(
2004$)
$
11,306
­$
1,188,815
­$
1,177,509
Number
Share
Number
Share
Number
Share
Companies
in
Analysis
181
100%
99
100%
280
100%

Compliance
costs
are
0%
of
sales
or
negative
137
76%
93
94%
230
82%

Compliance
costs
are
>
0
to
1%
of
sales
38
21%
6
6%
44
15%

Compliance
costs
are
>
1
to
3%
of
sales
5
2%
0
0%
5
2%

Compliance
costs
are
>
3%
of
sales
1
1%
0
0%
1
1%

Compliance
Cost­
to­
Sales
Ratios
Average
0.06%
0.00%
0.02%

Median
0.04%
­
0.01%
0.01%

Minimum
­
1.9%
­
1.14%
­
1.9%

Maximum
7.81%
0.04%
7.81%
45
Table
23.
Summary
Results
for
Small
Business
Analysis
for
Halogenated
Solvents
Residual
Risk
­
Regulatory
Option
Scenario
6
(
6,000
kg/
yr
MC)

Small
Large
All
Companies*

Total
Number
of
Companies
in
Analysis
181
98
279
Estimated
Annual
Compliance
Cost
Savings
(
2004$)
$
1,659,484
­$
229,215
$
1,430,269
Number
Share
Number
Share
Number
Share
Companies
in
Analysis
181
100%
98
100%
279
100%

Compliance
costs
are
0%
of
sales
or
negative
57
31%
76
78%
133
48%

Compliance
costs
are
>
0
to
1%
of
sales
104
57%
22
22%
126
45%

Compliance
costs
are
>
1
to
3%
of
sales
12
7%
0
9%
12
4%

Compliance
costs
are
>
3%
of
sales
8
5%
0
0%
8
3%

Compliance
Cost­
to­
Sales
Ratios
Average
0.5%
0%
0%

Median
0.05%
0%
0%

Minimum
­
1.9%
­
1.14%
­
1.9%

Maximum
15%
0.41%
15%

*
includes
those
companies
for
which
sales
and
employment
data
could
be
located
Table
24.
Summary
of
Economic
Impacts
Regulatory
Option
Number
of
Businesses
Affected
Number
of
Small
Businesses
Affected
Impacts
at
3%
or
Greater
CSR
 
Small
Businesses
Impacts
at
1%

or
Greater
CSR
 
Small
Businesses
Small
Businesses
with
Annualized
Costs
of
Less
Than
0.01
Percent
or
Having
Cost
Savings
Option
1
­
100,000
Kg/
yr
MC
equivalent
281
186
0
0
182
Option
2
­
60,000
Kg/
yr
MC
equivalent
279
181
0
0
178
Option
3*
 
40,000
Kg/
yr
MC
equivalent
277
179
0
0
173
Option
4**
 

25,000
Kg/
yr
MC
equivalent
281
186
1
2
154
Option
5
 
15,000
Kg/
yr
MC
equivalent
280
181
1
6
137
Option
6
 
6,000
Kg/
yr
MC
equivalent
279
181
8
20
57
*
Option
1
of
the
two
proposed
options
**
Option
2
of
the
two
proposed
options
47
47
Small
Business
Impact
Results
After
considering
the
economic
impact
of
today's
proposed
action
on
small
entities,
I
certify
that
this
action
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
For
these
co­
proposed
options,
there
are
3
small
firms
out
of
181
affected
that
have
annualized
compliance
costs
of
1
percent
of
sales
or
higher,
and
1
small
firm
with
annualized
compliance
costs
of
3
percent
or
higher.
In
addition,
a
large
number
of
small
firms
under
these
co­
proposed
options
will
experience
annualized
cost
savings
associated
with
applying
the
controls
to
meet
the
emissions
limits
included
in
these
options.
Based
on
this
information
on
small
business
impacts,
we
make
this
certification.

While
we
do
not
believe
these
options
will
lead
to
significant
economic
impacts
on
a
substantial
number
of
small
entities,
we
have
undertaken
efforts
to
mitigate
small
entity
impacts
as
part
of
this
rulemaking.
We
continue
to
be
interested
in
the
potential
impact
of
the
proposed
action
on
small
entities
and
welcome
comments
on
issues
related
to
such
impact.
References
Memo
from
Sorrels,
Larry,
U.
S.
EPA
to
Vogel,
Ray,
U.
S.
EPA.
"
Economic
Data
for
Area
Source
Categories
 
Title
V
Permit
Program
Rulemaking,"
June
17,
2004.

Michael
W.
Horrigan,
"
Employment
projections
to
2012:
concepts
and
context,"
Monthly
Labor
Review
127(
2):
12,
Bureau
of
Labor
Statistics,
February
2004.

Memo
from
Sarsony,
Chris
,
engineering­
environmental
Management,
Inc.
to
Dail,
Lynn,
U.
S.

EPA.
"
National
Cost
Impacts."
July
3,
2006.
United
States
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Health
and
Environmental
Impacts
Division
Research
Triangle
Park,
NC
Publication
No.
EPA
452/
R­
06­
006
August
2006
