BOARD MEETING DATE: April 5, 2002
AGENDA NO. 30

Stationary Source Committee

SYNOPSIS: 

The Stationary Source Committee met Friday, February 22, 2002. Following is a summary of that meeting. The next meeting will be March 22, 2002, at 10:30 a.m., in Conference Room CC8.

RECOMMENDED ACTION:

Receive and file.

Ronald O. Loveridge, Chairman
Stationary Source Committee

Attendance

The meeting began at 10:40 a.m. Present were Ron Loveridge, Committee Chair, Jon Mikels (departed at 11:40 a.m.), Leonard Paulitz, Cynthia Verdugo-Peralta (arrived at 10:55 a.m.), Norma Glover (arrived at 10:45 a.m.; departed at 10:55 a.m.; returned at 12:20 p.m.) and Jane Carney (arrived at 10:45 a.m.). William Burke was appointed to the committee by Ron Loveridge, viewed the meeting by videoteleconference, and departed at 11:10 a.m. There was a break in the meeting from 12:05 - 12:20 p.m. with Leonard Paulitz returning at 12:40 p.m.

INFORMATIONAL ITEMS

1. State Legislative Proposal on Hearing Board Orders for Abatement
   
   Peter Mieras, District Prosecutor, gave an overview of the 2002 State Legislative Concept – Orders for Abatement. The proposal would amend the Health and Safety Code (Sections 42450 and 42451) to give the Governing Board and Hearing Board the authority to issue orders for abatement to prevent future violations and authorize the Hearing Board to issue an emergency order for abatement upon 24-hour notice to the affected source without having to wait for the currently required 10-day noticing period to expire. A discussion of the issues raised by this concept ensued, with a determination that Peter Mieras, Hearing Board Chairman Ed Camarena, and Curtis Coleman would meet for the purpose of further refining this legislative concept.
   
    
2. Rule 1421 – Control of Perchloroethylene Emissions from Dry Cleaning Systems
   
   Jill Whynot, Planning & Rules Manager, gave an extended staff presentation on PAR 1421 - Control of Perchloroethylene Emissions from Dry Cleaning Systems. The Committee also heard from various interested parties regarding their comments on the draft rule.
   
   Key Issues:
   The key policy issue is whether to upgrade older perchloroethylene (perc) machines only or require replacement of perc machines with non-perc alternatives. In addition to cost and technical feasibility analysis, staff is also considering small business issues. Even the newest technology perc machines result in a remaining risk to the community, and there are additional public notification requirements under AB2588 to consider.
   
   Background:
   Perc dry cleaners have been regulated by District rules since 1980 and are also subject to federal National Emission Standards for Hazardous Air Pollutants and state air toxic control measures. Federal and state requirements are included in Rule 1421. Dry cleaners have reduced emissions approximately 80% over the past decade, but the remaining risk ranges depend on the age and technology of the machine: (50-188 in-a-million for 17 of the oldest machines; 50-100 in-a-million for approximately 1450 older machines; and 27-65 in-a-million for approximately 700 newer machines (not covered by R1401)).
   
   Staff has been working extensively with many of the associations and working groups, including many evening and one weekend night meeting. There are approximately 2,100 cleaners in the basin using perc, 70 solvent cleaners, 5 wet cleaners, and 1 carbon dioxide machine. The majority of dry cleaners are small family-run businesses, with long hours. There are many Korean owners and Latino workers. Typical shops have fewer than 5 employees. Revenues vary, but typically there is a relatively small profit margin. The industry believes there are more dry cleaners than the demand can support. Dry cleaners have high overhead expenses and some landlords now do not accept perc cleaners.
   
   Terminology was briefly discussed to explain the type of controls that vary by the age of machines. The vast majority (approximately 2/3 of the equipment) do not have state-of-the-art controls. Dry cleaners represent over ½ of perc emissions in the Basin. Other sources include film printing and processing (recently regulated under Rule 1425) and degreasers (also recently regulated under Rule 1122).
   
   Reasons why Rule 1421 is being evaluated for amendments:
   Perc is classified as a known animal carcinogen and a possible or probable human carcinogen by several health organizations. MATES II detected perc in the ambient air. The Air Toxic Control Plan and Rule 1402 identify perc dry cleaners as an industry to evaluate for additional reductions due to the potential risks to the community from these facilities. Dry cleaners are located in and near residential areas, shopping centers, schools, and day-care centers. There are alternatives to perc in use. Perc is an aggressive solvent.
   
   Dry cleaners have been using perc for years and are comfortable using it. There is residual risk from perc, and it also can cause ground water contamination.
   
   A map was shown highlighting dry cleaning facilities in the AQMD, as well as one showing dry cleaning facilities in Fullerton, as well as schools, day-care centers, and hospitals.
   
   There are alternatives to perc that are being used successfully. These include solvent cleaning (DF 2000, Green Earth, PureDry), wet cleaning, and CO₂ cleaning. Solvent cleaning is non-toxic, is similar in operation to perc, and is effective on all fabrics. Concerns with solvent cleaning include flammability, some contain VOCs, and more pre-stain treatment is needed. Wet cleaning is VOC and toxic free, the equipment costs less than other alternatives, it uses less energy, it cleans most fabrics, and it has a faster cycle time than perc or other solvents. Concerns with wet cleaning include problems cleaning some solvent-based stains, it requires training to avoid shrinkage and color transfer, and finishing takes longer. CO₂ cleaning is environmentally friendly, it has a faster cycle time, there is no odor, and stains can be treated post-cycle because no heat is involved. Concerns with CO₂ include costs, it does not clean acetates, and the technology is still in development.
   
   A table highlighting cost information was shown including capital costs, installation and maintenance costs, and information on labor and electricity compared to perc machines. Hydrocarbon machines, currently the most commonly used non-perc alternative, cost more than perc machines. Wet cleaning equipment is comparable to perc, and CO₂ equipment is much more expensive. Dry cleaning trends and scenarios being considered were discussed.
   
   Information was presented on trends in dry cleaning. In Germany, almost all new equipment is hydrocarbon or a combination of hydrocarbon and wet cleaning. One third of garments are wet cleaned. In the Bay Area, 16% of equipment is non-perc, mostly hydrocarbon, with a few wet cleaners. There has been an increase in alternatives in this area, especially with hydrocarbon machines.
   
   A graph was presented to highlight several rule proposals being evaluated. The discussion included the emission reductions and remaining risk for alternatives. Replacing older equipment with today’s more efficient perc machines on various schedules would result in 27-65 in a million for newer perc machines. Alternatives that would replace all perc machines with non-perc alternatives on various schedules would, over time, reduce risks to zero.
   
   Next steps were discussed, which included continuing the evaluation of technical, economic and policy issues, and responding to CEQA comments. A fourth consultation meeting will be held in March. The rule will be set April 5, 2002 for a Public Hearing in May (which may possibly be an evening meeting).
   
   Dr. Wallerstein explained that the rule has interesting challenges to balance technical and economic feasibility with an industry that is typified by many small "mom and pop" businesses. Staff wanted this committee to hear from both staff and interested parties so they can better understand the issues.
   
   Speakers:
   
   Tim Carmichael, Coalition for Clean Air
   
   Mr. Carmichael explained that perc is a possible carcinogen. The exposure from dry cleaners to the community is high. The environmental community believes that a 10-year phase-out is appropriate, reasonable, and feasible. He understands the cleaners have to change their methods and stated that AQMD should seek funds to assist in the transition.
   
   Martha Arguello, Physicians for Social Responsibility Los Angeles
   
   Physicians for Social Responsibility Los Angeles has approximately 2000 members dedicated to improving health for minority communities. They have been very involved in several campaigns, such as breast cancer detection and awareness. Ms. Arguello stated that a 10-year phase out is the best possibility being considered. There are significant costs for health care associated with perc. Perc is present in body tissue and fluids, and children are disproportionately affected. She said it is important to balance the small business needs, but cleaners have higher than acceptable risks. She recommended a mediated solution where all parties involved discuss their differences and try to work out a mutually acceptable rule.
   
   Jackie Smith, California Cleaners Association
   
   Dry cleaners are concerned about the environment and do not want to pollute. The industry has responded to prior rules and has worked with the District on Proposed Amended Rule 1421. The industry proposal, which was not easy to negotiate, is that they are willing to replace 2/3 of the existing equipment, but they want to remain with perc. As the new technologies continue to improve and gain acceptance, cleaners will switch, but they do not want to be forced that way by regulation. She cited an example of one dedicated wet cleaning facility that switched from two wet cleaning machines to one wet cleaner and a hydrocarbon machine.
   
   Ann Heil, Los Angeles County Sanitation District
   
   Perc is a very strong water contaminant. One quarter of a teaspoon can cause a violation at their entire treatment plant. Water samples still identify perc, which is most likely from dry cleaners. There are no adverse water impacts from any of the perc alternatives. A transition to non-perc alternatives is supported.
   
   Katy Wolf, Institute for Research and Technical Assistance
   
   Ms. Wolf has worked with dry cleaners since the 1970’s. Five years ago she would not have believed it was possible to phase out perc. She now believes it can be done. There are a variety of cost effective alternatives in place and demonstrated. Risks from perc over 25-in-one-million are too high. Dry cleaning equipment gets much less efficient over time and after 6-8 years of operation will likely have twice the emissions as a new machine. If all of the older equipment gets replaced, there will be an initial decrease in emissions, but over time emissions will increase the baseline. Going to non-perc alternatives also benefits the dry cleaners, with much less regulation for safety and water permits.
   
   Tim Malloy, UCLA Environmental Law Professor speaking as an individual.
   
   Mr. Malloy has been involved in studies of dry cleaners. He supports a 10-year phase out. Ten years represents the life of expectancy of perc machines, so a 10-year transition decreases the economic impacts for cleaners. He agreed with the previous speaker that perc machines increase emissions as they age, and mentioned the poor compliance history of dry cleaners.
   
   Scott Lutz, Bay Area Air Quality Management District
   
   In the Bay Area, many cleaners are voluntarily moving to hydrocarbon machines. They currently see 2 or 3 hydrocarbon permits for every perc permit. Most are going to DF2000 since there are some toxicity concerns for other solvents. Their rules are more stringent than AQMD rules by requiring enhanced ventilation for some facilities and requiring new perc facilities use vapor barrier rooms. In the Bay Area, there are about 12 wet cleaning machines, but no dedicated shops.
   
   Paul Cho, Korean Dry Cleaning and Laundry Association
   
   Paul said his industry is still recovering from the L.A. riots and the Northridge earthquake. The industry replaced transfer machines and is facing financial difficulty. Hydrocarbon machines cost more than perc with increased maintenance costs. Cleaners simply do not have the money for the extra expense. He has wet cleaning and stated that it takes two times as long to finish and two times as long to dry clothes.
   
   Board members asked questions of staff and other speakers and expressed their appreciation that so many people took time out of their schedules to come and talk with Board members. The Board members asked staff to continue looking into the issues that were raised.

All other agenda items were approved by consent. All written reports were acknowledged by the Committee.

The meeting was adjourned at 1:00 p.m.

Attachments

February 22, 2002 Committee Agenda (without its attachments)

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