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 27, 2021 Conference Call with Tony Pendola, Small Business Ombudsman, NCDEQ
On April 27, 2021 EPA held a conference call with Tony Pendola, Small Business Ombudsman for the North Carolina Department of Environmental Quality (NCDEQ) 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:
Tony Pendola, NC SBEAP
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 North Carolina's management of dry-cleaning facilities.
    Would like to see the perc dry cleaning rule simplified and/or brought up to date in a way that is applicable to current dry cleaning industry practices.
    Many facilities have been changing mode of operations from using perchloroethylene (perc) as the solvent chemical, to wet cleaning operations, which uses no perc.  
    Transfer machines are no longer used, and the 4[th] generation machines are typical.  
    From materials that Mr. Pendola shared with us and referenced during the call: 
        5[th] generation machines are most widely used in Europe as most dry cleaning machines made in Europe (particularly Germany). 
        In addition to having a refrigerated condenser and carbon absorber,  5[th] generation are closed-loop machines that have inductive fans and sensor-actuated lockout device that will not allow entry to the machine door, button trap, or filters until solvent vapors in the machine are below certain levels (generally 300 parts per million).
    It appears the prevalence of dry cleaning facilities will continue to decline due to fashion preferences and changes in clothing type. This decline has been further exacerbated by Covid-19 impact of work from home.
    Reclaimed perc in NC, their laws require closed fill capture system for putting perc in and taking it out. But this was difficult to achieve in practice, so the law actually discouraged perc reclamation.
    There is no N-Propyl-bromide (1-bromopropane or nPB) being used as solvent NC dry cleaning facilities. nPB had been billed as perc drop-in replacement, but the one facility that tried using it had heavy rusting issues.
    SBEAP dry cleaning calendar was created to help dry cleaning operators to stay in compliance with perc dry cleaning NESHAP.
    CO2 dry cleaning was touted as a perc alternative, but it was a large investment (including purchasing a supercritical pressure vessel)
    No co-residential dry cleaning remaining in NC. Used to be a few in some smaller town years ago.
    The State of North Carolina is a member of the State Coalition for Remediation of Drycleaners, an organization of states in which its members maintain a dry cleaning remediation program.
Mr. Pendola provided the following break-down of solvent use in the State of North Carolina:
198   Perchloroethylene (47%)
155   DF2000 (37%)
030   Kwik Dri
022   Ecosolve
004   Green Earth
002   Unknown
003   Solvon K4
001   Impress
001   Wet-Cleaning (Water)
001   Ktex
001   Gen-X
001   Mineral Spirits
001   Naptha
001   Petroleum (Generic)
420   Total facilities  
