FACT SHEET

PROPOSED AMENDMENTS TO AIR TOXICS STANDARDS FOR PERCHLOROETHYLENE DRY CLEANERS

FACT SHEET

ACTION
MORE INFORMATION
and HOW TO COMMENT

ACTION

On November 18, 2005, the Environmental Protection Agency (EPA) proposed amendments to its air toxics standards for perchloroethylene dry cleaners. Air toxics, also known as hazardous air pollutants, are known or suspected to cause cancer or other serious health or environmental effects. This proposed rule is posted at: http://www.epa.gov/ttn/oarpg/t3pfpr.html.
EPA will accept public comments on the proposal for 60 days following publication in the Federal Register. See the end of this fact sheet for instructions on submitting comments.
The proposed amendments, also known as residual risk standards, will reduce health risks that remain after implementation of the air toxics standards for this industry, which EPA issued in 1993. The proposal also addresses an 8-year technology review of the standards required by the Clean Air Act.
Perchlorethylene, also known as PCE, PERC, tetrachloroethyene and tetracholorethylene, is a solvent used in dry cleaning. Perchloroethylene is the only air toxic emitted from the dry cleaning process
There are 28,000 perchloroethylene dry cleaning facilities in the United States. Fifteen of these facilities are large facilities, considered "major sources," that use 2,100 gallons or more of perchloroethylene each year. These large facilities are covered by EPA's maximum achievable control technology (MACT) standards.
The other facilities are small, or "area" sources that use less than 2,100 gallons perchloroethylene per year. These smaller dry cleaners are covered by emissions standards known as generally available control technology (GACT) standards, also issued in 1993. These include about 1,200 dry cleaners located in residential buildings.
In preparation for this proposal, EPA completed a risk assessment to evaluate the risks remaining (called "residual risks") now that air toxics emissions have been controlled at dry cleaners.
EPA also completed a technology review to determine if it was necessary to revise the existing standards to account for recent developments in work practices, processes, or control technologies.
EPA is requesting comments and additional information to help better characterize exposures and risks from perchloroethylene dry cleaners located in residential buildings. The Agency will continue to assess risks from existing co-residential facilities and address them in a separate action if necessary.
EPA also is requesting comments on using technology-based standards rather than risk-based standards to reduce risk and emissions from area source dry cleaners. Technology-based standards could be standards similar to those now required by the New York State Department of Environmental Conservation.

WHAT THE PROPOSED AMENDMENTS WOULD REQUIRE

The proposed amendments would affect both large dry cleaners (major sources) and small cleaners (area sources) and include more stringent requirements for certain equipment and work practices to address the health risks identified in the risk assessment. The proposed amendments would also apply requirements for new or reconstructed sources to reflect improvements in emission control practices that have occurred since the 1993 rule.

Under the proposed amendments new and existing major source facilities would be required to:

Meet equipment standards, which include closed-loop dry cleaning systems with refrigerated condensers and carbon adsorbers.
Conduct enhanced leak detection and repair (LDAR) on a monthly basis, using a photoionization detector (or similar leak detection device) to detect perchloroethylene leaks from equipment, repair such leaks and maintain records.

New area source dry cleaners would be required to:

Meet equipment standards, which include closed loop systems with refrigerated condensers and carbon adsorbers. These are the same standards that would apply to major sources.
Conduct enhanced LDAR using a halogenated hydrocarbon detector to detect perchloroethylene leaks, repair such leaks and maintain records.

Existing area source dry cleaners would have to:

Eliminate all transfer machines. Transfer machines are considered the highest-emitting type of dry cleaning equipment. Approximately 200 of these machines currently are in use. o Conduct enhanced LDAR using a halogenated hydrocarbon detector to detect perchloroethylene leaks, repair such leaks and maintain records.

In addition, dry cleaners in residential buildings could not install any new perchloroethylene machines when current perc machines wear out. This moratorium will eventually phase out the use of perchloroethylene by dry cleaners in apartment buildings. As part of this proposal, EPA is soliciting comment on technology options to reduce risks from these facilities.

Most existing dry cleaners already are achieving the equipment standards these amendments would require. Affected facilities would have to comply with the new requirements within 90 days after publication of the final amendments in the Federal Register. Facilities that began construction between proposal of the 1993 MACT standards (December 9, 1991) and today's proposal will have 10 years from the date construction began to comply with the new requirements.
EPA is under a court order to issue a final rule by April 28, 2006.

PERCHLOROTHYLENE, HEALTH AND THE ENVIRONMENT

EPA's Science Advisory Board has identified perchloroethylene as a possible to probable human carcinogen. Exposure to perchloroethylene has been linked to the development of liver tumors in mice, and some epidemiological studies suggest exposure may be linked to a wide variety of cancers in dry cleaning workers.
Exposure to perchloroethylene also is associated with chronic, non-cancer health effects, including liver and kidney damage in rodents, and neurological effects in humans. Acute exposures can result in loss of coordination; eye, nose and throat irritation; and headache.
An estimated 9 million people reside within 10 miles of the major source facilities assessed for this proposed rule. Of these 9 million people, 375,000 have an estimated cancer risk greater than one in 1 million from perchlorothylene exposure; 1,200 of the 9 million people have a risk greater than 100 in 1 million.
These estimates are based on actual emissions and assume people are exposed for 70 years at their current place of residence. A maximum individual risk of 100 in 1 million is ordinarily considered the upper limit of acceptability for residual risk rules. Because people generally move several times during their lives, actual risk levels will be lower.
EPA estimates that most people living near freestanding area source dry cleaners have a cancer risk below 10 in 1 million. However, EPA estimates that the risk can be as high as 100. The estimated number of cancer cases associated with exposure to perchlorothylene from these free standing sources ranges from 0.4 to four cases per year.
Co-residential facilities, where apartments are located in the same building as a ground-level dry cleaner, pose a unique exposure scenario. Because these apartments are located very close to these dry cleaners, residents' exposures and their estimated cancer risks can be much higher than for typical area sources. Estimated inhalation cancer risks for people living in these buildings can be well in excess of 100 in 1 million. The estimated number of cancer cases associated with exposure to perchlorothylene from these co-residential facilities ranges from 0.3 to 2.2 cases per year. The proposed amendments are expected to reduce these risks (see benefits section of this fact sheet for more information).
As part of the proposed amendments, EPA also is soliciting comments on the potential for perchlorothylene emissions from drycleaners to adversely affect plants.

BENEFITS AND COSTS

Dry cleaners have reduced perchloroethylene usage by 30,000 tons a year since EPA's air toxics standards for perchlorothylene were implemented. As a result, emissions are estimated to have dropped by about 15,000 tons a year.
This reduction in perchlorothylene usage resulted from greater use of alternative dry cleaning solvents, the replacement of older dry cleaning machines, and state and industry programs to improve machine efficiencies and reduce perchlorothylene use.
The proposed residual risk standards would further reduce perchloroethylene emissions by an estimated 209 tons per year for major sources beginning in 2006, an estimated 70-percent reduction from baseline emissions (2000-2002). After implementation of the standards, EPA estimates that fewer than 13 people nationwide would have a cancer risk greater than 100 in 1 million from major sources, and about 55,000 people would have a cancer risk greater than one in 1 million. The maximum risk to an individual would be reduced by almost 90 percent, resulting in a maximum individual risk of less than 300 in 1 million.
Emissions from area sources are estimated to drop by about 2,700 tons per year as a result of the proposed amendments. The maximum individual cancer risks from existing area sources are expected to drop by about 20 percent as a result of these emission reductions, resulting in a maximum individual risk of about 175 in 1 million.
The proposed amendments are expected to eliminate cancer risks from new co-residential facilities. However, risk from existing co-residential facilities could possibly exceed 100 in 1 million after the amendments are implemented.
The proposed amendments will reduce perchloroethylene consumption and, therefore, reduce cost to facilities. EPA estimates an annualized cost savings of over $200,000 per year beginning in the first year of implementation for major sources complying with the proposed equipment and work-practice standards. For area sources, EPA estimates a cost savings of nearly $3 million per year across the industry.

EPA'S AIR TOXICS PROGRAM: TWO-PHASED REGULATORY APPROACH

The Clean Air Act requires EPA to regulate air toxics from large industrial facilities in two phases.
In the first, technology based phase, EPA develops standards for controlling the emissions of air toxics from sources in an industry group, or Asource category." These standards, known as maximum achievable control technology, or "MACT" standards, are based on the emissions levels of the better controlled and lower emitting facilities in an industry. EPA finalized the perchloroethylene dry cleaning MACT standards in September of 1993.
Within eight years of issuing MACT standards, EPA is required to assess the remaining health risks from each industry group to determine whether the standards protect public health with an adequate margin of safety. EPA must apply a risk-based approach determine whether more health-protective standards are necessary. If more protective standards are needed, EPA amends the MACT standards to add what is known as "residual risk standards."
To decide whether additional regulation under residual risk was necessary, EPA applied a two-step decision process described in the 1989 Benzene National Emissions Standards for Hazardous Air Pollutants. With this process EPA first determines whether the cancer risk to the individual most exposed to a given pollutant is acceptable, and second if existing standards protect the exposed population with an ample margin of safety. This decision framework is further described in both the EPA's Residual Risk Report to Congress (http://www.epa.gov/ttn/oarpg/t3/reports/risk_rep.pdf), and in the Air Toxics Risk Assessment Reference Library (http://www.epa.gov/ttn/fera/risk_atoxic.html).
The Clean Air Act also requires that EPA review the technology-based MACT standards every eight years and revise them, if necessary, to account for improvements in air pollution controls and or prevention.

FOR MORE INFORMATION AND TO SUBMIT COMMENTS

To download the notice from EPA's web site on the Internet, go to "Recently Actions" at the following address: http://www.epa.gov/ttn/oarpg/ramain.html.
Today's proposed action and other background information are also available either electronically in EPA's electronic public docket and comment system, or in hard copy at EPA's Docket Center, Environmental Protection Agency, Room B-102, 1301 Constitution Avenue, NW, Washington, DC (Docket ID No. OAR-2005-0155). The Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Public Reading Room is (202) 566-1744, and the telephone number for the EPA Docket Center is (202) 566-1742.
HOW TO COMMENT: EPA will accept comments for 60 days beginning when this proposal is published in the Federal Register. All comments should be identified by Docket ID No. OAR-2003-0161 and submitted by one of the following methods:

EDOCKET ( http://www.epa.gov/edocket ), EPA's electronic public docket and comment system, will be replaced by an enhanced Federal-wide electronic docket management and comment system located at www.regulations.gov. When that occurs, you will be redirected to that site to access the docket and submit comments. Follow the on-line instructions. ;
E-mail ( a-and-r-docket@epa.gov );
Facsimile ((202) 566-1741 and (919) 541-5689);
U.S. Mail (EPA Docket Center, Environmental Protection Agency, Mail code: 6102T, 1200 Pennsylvania Avenue, NW, Washington, DC 20460); or
Hand delivery (EPA Docket Center, Environmental Protection Agency, Room B-102, 1301 Constitution Avenue, NW, Washington, DC).

Please include a total of two copies. EPA requests a separate copy also be sent to the contact person identified below. In addition, please mail a copy of your comments on the information collection provisions to the Office of Information and Regulatory Affairs, Office of Management and Budget, Attn: Desk Officer for EPA, 725 17th St., NW, Washington, DC 20503.
For additional information contact Ms. Rhea Jones of EPA's Office of Air Quality Planning and Standards at jones.rhea@epa.gov.

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