| Update Air Monitoring Rules for
Dry Cleaners to Reflect Current Technology |
| Agency |
Environmental Protection Agency (EPA) |
| Submitter |
Small Business Environmental Assistance Program / Small
Business Ombudsman (SBEAP / SOB) National Steering Committee |
| Nominated |
February 28, 2008 |
| Description |
The Clean Air Act’s New Source Performance Standard (NSPS)
for petroleum dry cleaners, 40 C.F.R. §60.624, requires operators to
perform an initial test to verify that the dry cleaning machine is
operating properly. Additionally, Clean Air Act rules governing
perchloroethylene (perc) dry cleaners, 40 CFR §63.321, require operators
to use a halogenated hydrocarbon detector capable of detecting
concentrations of perc of 25 parts per million (ppm) or greater to
perform weekly inspections of their dry cleaning equipment. |
| Small entities affected |
Virtually all of the 28,000 dry cleaners in the United
States are small businesses. |
| Regulatory burden |
The required NSPS testing method was developed before
the modern closed-loop dry cleaning technology became widespread. The
testing method requires an operator to open the machine to sample the
emissions. However, most modern machines are closed-loop machines that
will automatically shut down if any of the components are disconnected.
Dry cleaners cannot conduct the required test in the manner specified by
the rule. Similarly, halogenated hydrocarbon detectors typically measure
ounces of refrigerant rather than ppm and most are not calibrated to
detect perc at concentrations down to 25 ppm. Dry cleaners using these
detectors therefore cannot meet the 25 ppm sensitivity requirement. |
| Proposed burden reduction |
EPA should (1) update the outdated NSPS testing methods
to reflect current equipment that is in use in the modern dry cleaning
industry, (2) clarify in 40 C.F.R. §63.321 that hydrocarbon detectors
for perc are not required to have a sensitivity down to 25 ppm. |
| Small entity benefits |
When outdated or inaccurate testing methods are revised,
dry cleaners will have a method for demonstrating compliance that fits
the modern equipment they use. |
| Status (8/28/08)
| Revising the New Source Performance Standard (NSPS) for petroleum dry cleaning equipment is a priority for EPA. When implemented, the NSPS revision will update emission testing requirements to work with modern dry cleaning machines. |
| Advocacy contact |
Keith Holman, advocacy@sba.gov |
