MEMORANDUM
From: 	Brian Storey, OAR/OAQPS/SPPD/MMG
To: 	PERC Dry Cleaning NESHAP Docket (Docket ID No. EPA-HQ-OAR-2005-0155)
Date:	May 5, 2021
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Subject: April 28, 2021 Conference Call with the State of Colorado Representatives
On April 28, 2021 EPA held a conference call with representatives from the State of Colorado 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:
Christine Hoefler, Colorado SBEAP Assistance Coordinator
Brian Storey, Project Lead
Ryan Callihan, Economist
Rhonda Wright, CTPG
Steven McLeod, RTI
The following information was shared with the group on the call regarding Colorado's management of dry-cleaning facilities.
    There were approximately 1,000 facilities registered and permitted in Colorado in 2005/6, and there are currently approximately 70 facilities using perc. Reductions due to factors such as economics/market trends, switching to alternative solvents, regulation changes (see second bullet below), and consolidation via drop off locations. These trends were happening even prior to Covid-19 pandemic.
    In 2014 Colorado changed regulation requiring any facility utilizing 250 pounds or more per year for all non-criteria reportable pollutants (e.g., HAP from perc) would have to report and have a permit, and this includes dry cleaning facilities.
    Unaware of any major source dry cleaning facilities in CO.
    In recent years, due to negative press and public response over remediation/hazwaste/water issues, landlords had been going after dry cleaners pressuring them to either move out or switch to "greener" solvents.
    The State of Colorado mails out compliance calendars to dry cleaners as an outreach program (primarily Korean-owned dry cleaners in the state). Also, CO air group works with hazardous waste group to do outreach.
    No additional fees for perc usage (outside the normal annual air emissions and hazardous waste fees).
    Dry cleaners in Colorado are using 4[th] and 5[th] generation machines. 
    The popular alternative solvents in use are DF2000 (hydrocarbons), carbon dioxide, green earth (siloxane-based), and petroleum. Regarding petroleum, noted that some facilities tried using petroleum as drop-in replacement for perc, but ran into corrosion/gasket fouling issues.
    Compliance issues typically related to recordkeeping and leak checks, general lack of understanding/language barriers. Generally, more hazardous waste issues than air.
  
