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 Kentucky Representatives
On April 28, 2021 EPA held a conference call with representatives from the State of Kentucky 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:
Courtney Shattuck, Division of Air Quality
Brian Storey, Project Lead
Keith Barnett, MMG Group Leader
Ryan Callihan, Economist
Steven McLeod, RTI
The following information was shared with the group on the call regarding Kentucky's management of dry-cleaning facilities.
    There are 8 regional offices in the State of Kentucky that perform inspections of the dry cleaning facilities.  Determining compliance with the Perchloroethylene Dry Cleaning NESHAP (40 CFR 63 Subpart M) falls under their field office branch.
    The Division of Compliance Assistance created a dry cleaning calendar. It provides facilities with a 2-year compliance calendar which allows facilities to record, weekly inspections, monthly usage of perchloroethylene (perc), twelve-month rolling averages, etc.  In addition, as an outreach to the dry cleaning owner and operators, the State provides a guidance document which has information on air, hazardous waste, and water regulatory compliance requirements.
    Generally, more and more dry cleaners moving away from perc and more drop off only locations. 
    Jefferson County (Louisville) has their own separate air program (so Ms. Shattuck does not have records for this area but would seek contact person(s) for dry cleaning there).
    Additional information regarding the number of facilities subject to Subpart M (including change in number since mid-2000s to current day), alternative solvents in use, types of machines in use, co-residential facilities (if any), number of major sources (if any), etc. would be provided at a later date.
  
