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 Rhode Island Representatives
On April 28, 2021 EPA held a conference call with representatives from the State of Rhode Island 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:
Joe Carola, State of Rhode Island, Compliance
Ciaran Imbusch, State of Rhode Island, Permitting
Chris Walusiak, State of Rhode Island, Office of Compliance and Technical Assistance
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 Rhode Island's management of dry-cleaning facilities.
    There were approximately 83 perc dry cleaning facilities in the State of Rhode Island in 2006, and there are approximately 39 current sources in the State.  None of these are major sources. No new per machines purchased and install in recent years.
    Many facilities switching from perc to other solvents such as hydrocarbons, K4, Green Earth, and petroleum.
    Many facilities have consolidated operations, turning previous perc users to drop-off facilities, where garments are collected at various sites and then transferred to a central location where cleaning takes place.
    Some facilities have closed all together due to economic challenges.
    Some of the problems encountered during inspections were noted to be related to language barriers, for example, understanding where to purchase colorimetric detection tubes.  Additionally, lack of the proper recordkeeping was also noted.
    The most common alternative solvent in use in the State is high flash point hydrocarbons.
    Mostly close loop 4th and 5th generation machines (less than five 5th generation machines)
  
