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 29, 2021 Conference Call with the State of New York Representatives
On April 29, 2021 EPA held a conference call with representatives from the State of New York 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:
Ed Horick, NYDEP
Nick Onderdonk-Milne, NYDEP
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 Ney York State's management of dry-cleaning facilities.
    General decline in dry cleaning businesses, mainly due to customer habits, some also due to landlord pressures about having perc dry cleaning on their properties. These businesses are difficult to relocate (customer bases)
    NYFD have codes more stringent that national standards. Makes it difficult to site alternative solvent machines (particularly hydrocarbon machines)
    In 2006 there were approximately 1,500 facilities in the State.  Currently there are 1,200 facilities statewide (with more than half being in NY City)
    150 co-located residential facilities have been shut down since the 2006 rule. NY updated their rule in 2018 to include co-located residential facility phase out (no perc in co-located residential after 12/21/2020). Some co-located residential are yet to be inactivated in the database (so the 1,200 facilities is likely more than what's actually in operation, inspection verifications in progress)
    In NY if someone wants to relocate a perc machine it must be <10 years and be a stand-alone location on a property owned by the operator
    Used to only require major facilities to test end of cycle concentrations in the drum, now every perc machine owner must do monthly sampling if 4[th] generation machine (with colorimetric detector tube sampler or photo ionization detector). 
 Older generations cannot do this type of testing.
 300 ppm in drum is the limit
    Yearly compliance inspections done by third-parties (which are funded by the regulated facilities)
    No 3[rd] generation machines allowed after 12/31/2021. In 2017 there were ~20 3[rd] generation machines. Currently have eight (these will be gone by the end of 2021).
    Have seen no breakthrough changes in design that would limit emissions since mid-2000s (last technology review)
    The typical price for perchloroethylene (perc) in the State is $27 per gallon.
    Decommissioning of a perc machine ~$1.5k, removing ~$6k, and ~$27k minimum for a new perc machine. Alternative solvent machines generally costs more (in NYC fire protection sprinkler systems required for flammable alternative solvents).
    In some instances, transitioning to alternative solvents has met some restrictions due to fire protection requirements to meet fire codes.  This is specifically true when switching to high flash point hydrocarbons.
    New York performs analyses on alternative solvents and maintains an approved alternative solvent list.
    New machines must have statement of compliance for the machine model under consideration for install. 
    Are not aware of any 5[th] generation (door lock out mechanism until cycle ends) in NY from inspection findings. Are aware the German manufacturer produces these.
    N-propyl bromide (1-BP) is not allowed as dry cleaning solvent in NY due to toxicity
    It is estimated that there are 1 or 2 major sources (industrial cleaners) under the Dry Cleaning NESHAP in the State. But none are major based on perc solely.
    The State recommends dry cleaners attend a 16-hour training class.
    To operate a perc dry cleaning facility in NY, the owner or manager must have a valid Owner/Manager certificate. To operate a perc dry cleaning machine, the operator must have a valid Operator certificate.
  
