MEMORANDUM
From: 	Brian Storey, OAR/OAQPS/SPPD/MMG
To: 	PERC Dry Cleaning NESHAP Docket (Docket ID No. EPA-HQ-OAR-2005-0155)
Date:	May 12, 2021
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Subject: May 6, 2021 Conference Call with the State of California Representatives
On May 6, 2021 EPA held a conference call with representatives from the State of California to discuss the National Emission Standards for Hazardous Air Pollutants from PERC Dry Cleaning Facilities (Dry Cleaning NESHAP).  The following people participated in the call:
Greg Harris, CARB
Eugene Rubin, CARB
Mei Fong, CARB
Robert Krieger, CARB
John Katz, EPA Region 9
Brian Storey, Project Lead, OAR
Ryan Callihan, Economist, OAR
Larry Sorrels, Economist, OAR
Kelly Summers, OCSPP
Albert Monroe, OCSPP
Amy Shuman, OCSPP
Steven McLeod, RTI
The following information was shared with the group on the call regarding California's management of dry-cleaning facilities.
    Dry-cleaning facilities in CA are permitted at the local level and managed by the individual districts in the State. Includes perc and hydrocarbon dry cleaners. Hydrocarbon facilities regulated by local area districts with requirements based on solvent use rules or specific local dry cleaning rules.
    In 2007, California passed Airborne Toxic Control Measures (ATCM) legislation, which phased-out the use of perchloroethylene (perc) within 15-17 years (based on the typical useful life of a machine).  This phase-out was written into the air permits of dry-cleaning facility air permits. Only a handful of per cleaners not yet phased out and by 2023 should have no perc dry cleaning in CA.
    Wet cleaning or CO2 installations don't require permits.
    The State of California created a grant program to provide assistance to those cleaners who decided to switch from perc to alternative solvents. 140 grants were issued. $10k if convert to wet cleaning or CO2 cleaning. Also offer an additional $7.5k if the facility conducts a demonstration of their new machine.
    Most facilities have gravitated to using hydrocarbon solvents (DF 3000, GreenEarth, D5/silaxane). N-propyl bromide (1-BP) in use at ~2 facilities.
    The South Coast Air Quality Management District (SCAQMD) intends to eliminate the use of perc by the year 2020 (with some exception given due to COVID).  The State of California intends to have a complete phase-put of perc by the year 2023.
    The SCAQMD performs analyses on alternative solvents and maintains an approved alternative solvent list.
    New solvent candidates are sent to CA Office of Environmental Health Hazard Assessment (OEHHA) for toxicology evaluation.
    Approximately 4,000 facilities in the 1990s (2,300 were perc). Around 2006 the total number dropped to around 3,000. In 2019 there were 300 perc users still operating in 2019 (of which South Coast had 270)
 Currently 300 total permitted dry cleaners. This figure does not include the South Coast and Bay Area locations. 
    Hydrocarbon machines are slightly more expensive than a new PERC machine and wet cleaners are less expensive
    CARB does not have info on specific generations of machines in use, the local area districts would have this info
    CARB has not seen real challenges with compliance
    CARB charges $12/gal fee on PERC (assists with replacement equipment)
 Cost of PERC is about $40 per gallon
 Assumed 15-year useful life of machine for PERC phase out
 Estimated that the cost of a new wet cleaning systems is $80  -  $100 thousand when starting the PERC phase out
 The new systems Includes 4 pieces of equipment
 Prices have decreased to around $40k recently
    CA evaluated health risks from dry cleaning facilities. Decided to phase out co-located residential facilities first, then based on the age of the machine the slow phase-out proceeded.

