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 Tennessee Representatives
On April 29, 2021 EPA held a conference call with representatives from the State of Tennessee 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:
Charles Rowan, Division of Remediation, TNDEC
Justin Dolzen, Air Permitting, TNDEC
Donovan Grimwood, Tennessee SBEAP Small Business Ombudsman
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 Tennessee's management of dry-cleaning facilities.
    Tennessee requires all active dry-cleaning facilities to register with the State.  Registration fees go toward a voluntary clean-up program. Also charges a fee for solvent 
    The State issues general air permits of dry-cleaning facilities and performs inspections of those permitted facilities. A few years ago, TN switched from individual standard permits to these general permits for dry cleaners (the expiration for the general permits are 2/1/2027).
    Tennessee classifies cleaning solvents into two categories: where perchloroethylene is classified as "dense" (i.e., heavier than water), and some of the alternative solvents are classified as "light" meaning they float on water (e.g., DF2000, EcoSolv, Stoddard, oxygenated constituents) 
    Approximately 50 percent of the dry cleaners are using perc, and 50 percent are using hydrocarbons.
    Over the last few years (pre-pandemic) the State saw a decrease in the number of facilities at a rate of 5-10 facilities closing business [per year.  As a result of COVID (2020), it is estimated the State has seen the closing of 25 -30 facilities.
    Estimated that a new dry cleaning machine would cost between $60  -  $100 thousand (new machines primarily hydrocarbon machines)
    Estimated that there are currently 195 registered dry cleaners in the state. A decrease from 2016 when there were 286
 Currently there are roughly 69 perc subpart M facilities (which does not include data from the metro areas)
 2 stoddard hydrocarbon belly washers being used in TN
 Still some transfer hydrocarbon machines in use
 No Title V dry cleaning facilities (largest facility named Rowland in Jackson, TN uses hydrocarbon not perc)
 In the general database APC has 81 dry cleaners that are permitted, some of these may be petroleum dry cleaners potentially subject to NSPS
 TN uses 3 categories for dry cleaning machines: 
 dry-to-dry installed on or before 12/9/1991 that use <140 gal of perc
 dry-to-dry machines installed after 12/9/1991 but before 2005 equipped with a refrigerated condenser
 dry-to-dry machines installed after 2005 and must follow the differing requirements under subpart M
    Have seen conversions from full service to drop off/pick up only locations
    No hydrocarbon drop-in to perc machines (or vice versa). Would have to get entirely new machines
    No dry cleaners using n-propyl bromide as solvent (a couple of facilities tried it, but no longer in use)

