Summary
of
the
Nationwide
Estimated
Cost
Impacts
for
Halogenated
Solvent
Cleaning
1.0
INTRODUCTION
On
December
1994,
the
Environmental
Protection
Agency
(
EPA)
developed
National
Emission
Standard
for
Hazardous
Air
Pollutants
(
NESHAP)
for
halogenated
solvent
cleaning.
The
technology­
based
standard
controlled
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.
Halogenated
solvent
cleaning
does
not
constitute
a
distinct
industrial
category,
but
is
an
integral
part
of
many
major
industries.
The
HAP,
TCA,
CT
and
C
are
no
longer
used
in
solvent
cleaning
machines.

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.

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
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
are
expected
to
provide
further
reductions
of
MC,
PCE,
and
TCE
beyond
the
1994
NESHAP,
based
on
application
of
a
facility­
wide
MC,

PCE
and
TCE
emission
standards.

The
purpose
of
this
memorandum
is
to
summarize
the
nationwide
cost
impacts
associated
with
the
proposed
options
or
emission
caps
developed
to
control
emissions
from
halogenated
solvent
cleaning.
Costs
and
emission
reductions
are
presented
for
each
option
developed
during
the
analytical
phase.
These
control
option
requirements
were
developed
based
on
a
residual
risk
analysis
determining
cancer
and
non­
cancer
affects
to
human
health.
The
options
are
a
beyond
the
MACT
floor
options.
Costs
are
presented
in
1998
dollars
and
cost
effectiveness
estimates
are
presented
in
1998
dollars
per
kilogram
of
hazardous
air
pollutants
(
HAP)
reduced
($/
kg).
The
methodology
for
calculating
cost
effectiveness
is
based
on
the
1.1
BACKGROUND
The
halogenated
solvent
cleaner
NESHAP
requires
batch
vapor
solvent
cleaning
machines
and
in­
line
solvent
cleaning
machines
to
meet
emission
standards
reflecting
the
application
of
the
maximum
achievable
control
technology
for
major
and
area
sources;
area
source
batch
cold
cleaning
machines
are
required
to
achieve
generally
available
control
technology.
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.
The
halogenated
solvent
cleaning
NESHAP
was
estimated
to
reduce
nationwide
emissions
of
hazardous
air
pollutants
(
HAP)
from
halogenated
solvent
cleaning
machines
by
77,400
Mg/
yr
(
85,300
tons
per
year),
or
63
percent
by
1997
compared
to
the
emissions
that
would
result
in
the
absence
of
the
standards.

2.0
RISK
ANALYSIS
RESULTS
The
residual
risk
analysis
addressed
halogenated
solvent
cleaning
machines
subject
to
the
1994
MACT
standards
(
40
CFR
Part
63
Subpart
T)
and
estimates
potential
risks
due
to
HAP
emissions
from
sources
that
emit
one
or
more
of
the
regulated
HAPs.
The
risk
assessment
did
not
include
the
HAPs
carbon
tetrachloride
and
chloroform
because
their
usage
was
phased
out
after
the
MACT
was
promulgated.
The
assessment
only
considered
the
inhalation
pathway
as
the
primary
route
of
exposure
for
humans
because
all
of
the
four
remaining
HAPs
are
highly
volatile
compounds.
In
addition,
multimedia
fugacity
modeling
results
indicate
that
the
majority
(
over
99
percent)
of
each
of
these
four
source
category
HAP
partitions
preferentially
to
air
rather
than
water,
soil,
or
sediment.
The
analysis
estimated
the
potential
for
emissions
from
this
source
category
to
result
in
increased
cancer
risk
and
chronic
and
acute
(
i.
e.,

one­
hour)
non­
cancer
hazard.

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
lifetime
cancer
risk
and
chronic
non­
cancer
HI
as
well
as
distributions
of
cancer
and
noncancer
risks
across
the
exposed
populations
were
calculated
for
each
facility.
Results
have
been
scaled­
up
proportionally
to
reflect
results
for
the
1,900
facilities
in
the
source
category.
A
summary
of
the
estimated
lifetime
cancer
risks
can
be
found
in
the
Risk
Report
for
Halogenated
Solvent
Cleaning.

The
numbers
of
facilities
in
the
source
category
which
pose
various
levels
of
maximum
individual
lifetime
cancer
risks
are
presented
in
Table
2
of
this
preamble.
These
results
show
that
source
category
emissions
from
539
facilities
(
approximately
28
percent
of
the
sources
in
the
source
category)
were
estimated
to
pose
a
maximum
incremental
increase
in
lifetime
cancer
risk
at
or
above
one
in­
a­
million.
Of
the
539
facilities,
124
were
found
to
pose
a
maximum
cancer
risk
greater
than
or
equal
to
ten
in­
a­
million
and
seven
of
these
facilities
were
estimated
to
pose
a
maximum
cancer
risk
of
100
in­
a­
million
or
more.
Six­
hundred
ninety
facilities
emit
only
the
non­
carcinogen,
1,1,1­
TCA,
and
therefore
pose
no
cancer
risk.
Note
that
the
risk
estimates
summarized
in
Table
2
of
this
preamble
are
the
maximum
cancer
risk
estimates
for
each
facility;
the
estimated
risk
for
the
majority
of
the
individuals
exposed
at
each
facility
will
be
less.

3.0
PROPOSED
ADDITIONAL
CONTROLS
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.
Records
of
the
calculation
sheets
showing
how
the
annual
emissions
were
determined
must
be
maintained.

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).
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.

Emission
levels
for
regulatory
option
scenarios
were
derived
based
on
the
risk
assessment
results
for
the
baseline
scenario
and
an
analysis
of
maximum
individual
cancer
risks
(
see
Section
5).
To
develop
the
risk­
based
regulatory
option
scenarios,
all
emissions
rates
in
the
assessment
database
were
first
converted
to
methylene
chloride
(
MC)
equivalents
based
on
the
relative
cancer
potency
of
the
HAPs
emitted.
For
the
assessment
of
cancer
risks,
the
cancer
potency­
weighted
MC
equivalent
emissions
rate
was
calculated
as
the
estimated
post­
MACT
emissions
in
kg/
yr
or
lb/
yr
times
the
unit
risk
estimate
(
URE)
for
the
HAP
divided
by
the
URE
for
MC.

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
MC­
equivalent
emissions
to
no
more
than
100,000
kg/
yr
(
220,000
lbs/
yr).

°
Regulatory
Option
Scenario
2
­­
Assumes
that
all
sources
would
reduce
MC­
equivalent
emissions
to
no
more
than
60,000
kg/
yr
(
132,000
lbs/
yr).
°
Regulatory
Option
Scenario
3
­­
Assumes
that
all
sources
would
reduce
MC­
equivalent
emissions
to
no
more
than
40,000
kg/
yr
(
88,000
lbs/
yr).

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

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

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

4.0
COST
ANALYSIS
The
baseline
cost
analysis
for
the
halogenated
solvent
cleaning
source
category
used
facility
data
from
a
database
that
included
1,167
sources,
but
not
all
sources
had
adequate
information
for
analysis.
This
assessment
database
represents
approximately
61
percent
of
the
1,900
facilities
in
the
source
category.
The
numbers
of
facilities
in
the
source
category
which
pose
various
levels
of
maximum
individual
lifetime
cancer
risks
are
presented
in
Table
1.
These
results
show
that
source
category
emissions
from
539
facilities
(
approximately
28
percent
of
the
sources
in
the
source
category)
were
estimated
to
pose
a
maximum
incremental
increase
in
lifetime
cancer
risk
at
or
above
one
in­
a­
million.
Of
the
539
facilities,
124
were
found
to
pose
a
maximum
cancer
risk
greater
than
or
equal
to
ten
in­
a­
million
and
seven
of
these
facilities
were
estimated
to
pose
a
maximum
cancer
risk
of
100
in­
a­
million
or
more.

Sixhundred
ninety
facilities
emit
only
the
non­
carcinogen,
1,1,1­
TCA,
and
therefore
pose
no
cancer
risk.
Note
that
the
risk
estimates
summarized
in
Table
2
of
this
preamble
are
the
maximum
cancer
risk
estimates
for
each
facility;
the
estimated
risk
for
the
majority
of
the
individuals
exposed
at
each
facility
will
be
less.
Table
1:
Number
of
Units
Subject
to
Control
and
Not
Subject
to
Control
for
Each
of
the
Six
Compliance
Options
6,000
MC
15,000
MC
25,000
MC
40,000
MC
60,000
MC
100,000
MC
Group
#
%
of
Grand
Total
#
%
of
Grand
Total
#
%
of
Grand
Total
#
%
of
Grand
Total
#
%
of
Grand
Total
#
%
of
Grand
Total
Total
for
Units
in
NEI
subject
to
control
beyond
MACT
523
51%
381
37%
298
29%
232
23%
154
15%
94
9%

Total
for
units
in
NEI
NOT
subject
to
control
beyond
MACT
494
49%
636
63%
719
71%
785
77%
863
85%
923
91%

Grand
Total
of
All
Units
in
NEI
1017
100%
1017
100%
1017
100%
1017
100%
1017
100%
1017
100%

Table
2:
Number
of
Units
Assigned
to
Each
Control
Option
for
Each
of
the
Six
Compliance
Options
6,000
MC
15,000
MC
25,000
MC
40,000
MC
60,000
MC
100,000
MC
Control
Option
#
%
of
Grand
Total
#
%
of
Grand
Total
#
%
of
Grand
Total
#
%
of
Grand
Total
#
%
of
Grand
Total
#
%
of
Grand
Total
Vacuum
PCE
to
MC
PCE
to
TCE
TCE
to
MC
Retro
 
1.5
FBR,
WC,
FRD
Retro
 
1.5
FBR
287
25
39
72
47
53
55%

5%
7%
14%

%
9
%
10
177
20
37
47
63
37
46%

5%
10%
12%
17%
10%
115
17
29
44
45
48
39%

6%
10%
15%
15%
16%
71
15
16
40
45
45
31%

6%
7%
17%
19%
19%
45
10
16
33
14
36
29%

6%
10%
21%

9%
23%
31
5
15
18
14
11
33%

5%
16%
19%
15%
12%

Total
for
Units
in
Nei
Subject
to
Control
Beyond
Mact
1017
100%
1017
100%
298
100%
232
100%
154
100%
94
100%
Table
3:
Emission
Reductions
in
Tons
by
Control
Option
for
Each
of
the
Six
Compliance
Options
6,000
MC
15,000
MC
25,000
MC
40,000
MC
60,000
MC
100,000
MC
Control
Option
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%

Vacuum
PCE
to
MC
PCE
to
TCE
TCE
to
MC
Retro
 
1.5
FBR,
WC,
FRD
Retro
 
1.5
FBR
4,675
254
38
182
69
54
88%

6%
0%
3%
1%
1%
4,675
254
38
182
69
54
86%

6%
0%
3%
4%
1%
3,409
237
81
132
175
124
82%

7%
1%
3%
4%
3%
2,911
220
42
93
238
123
80%

7%
0%
3%
7%
3%
2,318
183
70
160
121
155
77%

7%
1%
5%
4%
5%
1,837
180
98
35
238
85
74%

9%
2%
1%
10%

3%

Total
for
Units
in
NEI
Subject
to
Control
Beyond
MACT
5,273
100%
4,708
100%
4,158
100%
3,526
100%
3,008
100%
2,473
100%

Overall
Percent
Reduction
From
Total
6,047
Tons
in
NEI
87%
78%
69%
60%
50%
41%

Table
4:
Emission
Reductions
in
Tons
by
Hap
for
Each
of
the
Six
Compliance
Options
6,000
MC
15,000
MC
25,000
MC
40,000
MC
60,000
MC
100,000
MC
Control
Option
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%
Emission
Reduction
(
Tons)
%

MC
TCE
PCE
850
3,092
1,331
16%
59%
25%
699
2,721
1,289
15%
58%
27%
602
2,317
1,239
14%
56%
30%
524
1,932
1,170
14%
53%
32%
453
1,472
1,083
15%
49%
36%
439
1,053
981
18%
43%
40%

TOTAL
5,273
100%
4,708
100%
4,158
100%
3,626
100%
3,008
100%
2,473
100%
Table
5:
Costs
to
Units
Subject
to
Control
for
Each
of
the
Six
Compliance
Options
Costs
to
Units
Subject
to
Control
Beyond
MACT
6,000
MC
15,000
MC
25,000
MC
40,000
MC
60,000
MC
100,000
MC
Total
Capital
Costs
$
118,319,131
$
74,043,063
$
48,973,569
$
31,262,367
$
19,322,823
$
13,312,783
Annualized
Capital
Costs
$
11,227,944
$
7,042,555
$
4,670,995
$
2,996,757
$
1,851,536
$
1,271,375
O&
M
Costs
$
251,435
$
209,325
$
177,602
$
190,232
$
102,485
$
55,617
Solvent
Savings
($
10,036,034)
($
8,945,132)
($
7,861,021)
($
6,814,394)
($
5,591,568)
($
4,522,658)

Total
Annual
Emission
Control
Costs
$
1,443,345
($
1,693,252)
($
3,012,424)
($
3,627,406)
($
3,637,548)
($
3,195,667)

For
Option
1,
we
estimate
that
66
percent
of
the
affected
parent
companies
are
small
(
186
out
of
281)
according
to
the
SBA
size
standards.
Of
these
small
companies,
none
of
these
is
expected
to
have
annualized
compliance
costs
of
more
than
1
percent
of
sales.
For
Option
2,
we
estimate
that
66
percent
of
the
affected
parent
companies
are
small
(
186
out
of
281)
according
to
the
SBA
size
standards.
Of
these
small
companies,
3
of
these
are
expected
to
have
annualized
compliance
costs
of
more
than
1
percent
of
sales.
Of
these
3,
one
is
expected
to
have
annualized
compliance
costs
of
more
than
3
percent
of
sales.
