TurboDri@aol.com

03/23/2006 04:12 PM

To

Group A-AND-R-DOCKET@EPA

cc

bcc

Subject

Attention Docket ID No. OAR-2005-0155

Attention Docket ID No. OAR-2005-0155

Comments are in attached file.

PROPOSED REVISION TO THE

**NATIONAL PERCHLOROETHYLENE AIR EMISSION STANDARDS**

**FOR DRY CLEANING FACILITIES**

***DOCKET ID NUMBER OAR 2005-0155***

> *Comments by:*
>
> ***ILSA Machines Corp. (IMC)***
>
> ***NFPA 32 Committee Person***
>
> Stephen Langiulli

March 23, 2006

E-mail - <a-and-r-docket@epa.gov>

Attn: Docket ID No. OAR-2005-0155

Fax - 202-566-1741

Comments: Identify by Docket ID #OAR-2005-0155

Generally, ILSA Machines Corp. (IMC) believes that a person,
association, group, or entity selecting to comment on the proposed
NESHAP rulemaking can not effectively accomplish the task if their
comments are isolated to the individual items the proposal seeks public
comments on. The proposal in itself is difficult to understand in its
request for comments to proposed options in respect to performance
standards within a given source category.

As a technical expert, with many years of manufacturing experience in
the industry, the proposal as published proves difficult to arrive at a
clear and concise direction to the docket's intent. And in the absence
of standardize industry terminology within the docket, IMC was forced to
spend considerable time researching its context.

For IMC's comments it was necessary to review the existing rule of
NESHAP September 22, 1993, Clean Air Act 1990 Section 112, and the
Eastern Research Group Memorandum, Background Information Document,
November 14, 2005. It should be further noted the unfairness to the
public wishing to comment on the proposal presented, and the short time
allotted to evaluate, address and comment. (December 21, 2005
publication date to March 23, 2006 deadline for comment.)

As a stakeholder in the industry, IMC was contacted by ERG many times
during the past 2 years to provide information to the research.
Additional time was allotted for prearranged conference calls with EPA
and industry stakeholders.

The proposal context and its request for comments indeed require further
research and explanation to its options. However, the deadline of
submitting comments is an obstacle. Options stated do not provide
thorough explanations of methods to which they can be implemented. This
aspect is troubling, since the option of complete ban of PCE requires
only implication by EPA with a method to assist in the cost of its
implementation. IMC also expects individual states, who embrace a ban
option, to use the proposal as catalysis for their rule making. All
non-banning options in the proposal are presented in the absence of
methods and standards to achieve their goal. It is apparent this aspect,
does not reflect the industry accomplishments thus far in reducing PCE
emissions.

Considering that EPA does not have data, other than marketing statistics
for the alternatives to PCE machines, as it is required by CAA112 (a)
(5) and (g)(1)(A), any option with a focus on a PCE ban or reduction,
based on an alternative technology, can be deemed challengeable.

Therefore, with these submitted comments, IMC asks for an oral
presentation of data, ideas, and performance case studies in support of
a technology base standard which allows for the use of PCE in all source
categories, that in retrospect produce a reduction in residual risk
factors the NESHAP is attempting to propose, and thereby allowing
individual state Air Divisions to have at their resources the benchmark
reduction of emission with state-of-the-art equipment and the proven
techniques to achieve it.

*Our comments are arranged in Sections as follows:*

EC -- Editorial Mistakes in Proposal

C1 -- Comments to data collected by Eastern Resource Group

Background Information Docket, November 14, 2005 - Incomplete

C2 -- Conclusion of ERG's Research -- Omitted

C3 -- Performance of PCE Machines

C4 -- Alternatives to PCE

C5 -- Rationale to Our Comments

C6 -- 11 Point Condensed Comments

Proposal Editing Comments (EC)

**Proposal Section I (B)** *"What are PCE Drycleaning Facilities?"*

*Commenter Section*

EC.1 For major area sources, PCE consumption is identified as
"PURCHASE". For large and small area sources PCE consumption is
identified as "USE". The proposal should conform to either "PURCHASE" or
"USE" for a clear interpretation.

EC.1.2 Regardless of how consumption is identified, ("PURCHASE" or
"USE"), NESHAP considers consumption as "emitted" and the amounts as
stated are based on 12 consecutive month period, and not by mass balance
methodology.

Interpretation by interested parties, such as authorities having
jurisdiction (AHJ), it can be considered that if an area source
purchases or uses over their maximum allowable gallons as pertains to
their source identity (major, large, or small) within 12 consecutive
months, the source is now out of compliance.

The proposal, and probably even the existing 1993 NESHAP, does not make
a reference clearly to a source adding new equipment or replacing older
equipment which then would require an initial filling of PCE. The
initial filling of machines over 40 lbs dry weight rated capacity can
range from 150 gallons to 500 gallons per machine.

**Proposal Section IV (B)** *"Alternative Performance -- Based Standard
for* *Existing Major*

*Sources*"

EC.1.3 It is stated that the annual PCE usage would be calculated based
on the amount of PCE purchased during a calendar year, adjusted for the
PCE in use and storage at the beginning and end of the calendar year.

Here the NESHAP does make a provision of adjustments, if an area source,
selects to portion his operating equipment to a performance standard.
The reduction of PCE is suggested to only happen if this were
accomplished by a change in solvent and not from a change in PCE
operating equipment, from outdated to state-of-the-art.

> **Proposal Section III (J)** "*What is our proposed decision on
> co-resident area*
>
> *sources"?*

EC.2 The 4^th^ paragraph, sentence starting with cost estimator would be
much lower... alternative garment cleaning options utilizing
**"non-flammable"** solvents....

> The word/phrase **"non-flammable"** in the context and category the
> proposal identifies, makes reference that alternative drycleaning
> solvents are flammable. Presently flammable solvents for drycleaning
> are banned from use throughout the country.
>
> All alternatives for PCE within the drycleaning industry, with the
> exception of liquid carbon dioxide and water, are **combustible**.
>
> CAA112(r)(7)(C) -- *"regulations promulgated pursuant to this
> subsection shall to the maximum extent practicable, consistent with
> this subsection, be consistent with the recommendation and standards
> established by American Society of Mechanical Engineers (ASME),
> American National Standards Institute (ANSI) or American Society of
> Testing Materials (ASTM).........."*
>
> (NFPA 30), Sec. [3.3.25.1]{.underline} Edition 2003 - ***Combustible
> Liquid***
>
> *Any liquid that has a closed-cup flash point at or above 100ºF
> (37.8ºC), as determined by the test procedures and apparatus set forth
> in 1.7.4 Combustible liquids are classified as Class II or Class III
> as follows: (1) Class II Liquid -- any liquid that as a flash point at
> or above 100ºF (37.8ºC) and below 140ºF (60ºC); (2) Class IIIA -- any
> liquid that has a flash point at or above 140ºF (60ºC), but below
> 200ºF (93ºC); (3) Class IIIB -- any liquid that has a flash point at
> or above 200ºF (93ºC).*

(NFPA 30), Sec. [3.3.25.2]{.underline} Edition 2003 **- *Flammable
Liquid***

> *Any liquid that has a closed-cup flash point below 100ºF (37.8ºC), as
> determined by the test procedures and apparatus set forth in 1.7.4.
> Flammable liquids are classified as Class I as follows: Class 1
> Liquid- any liquid that has a closed-cup flash point below 100ºF
> (37.8ºC) and a Reid vapor pressure not exceeding 40 psia (2068.6 mm
> Hg) at 100ºF (37.8ºC), as determined by ASTM D 323, Standard Method of
> Test for Vapor Pressure of Petroleum Products (Reid Method). Class 1
> liquids are further classified as follows: (1) Class IA liquids --
> those liquids that have flash points below 73ºF (22.8ºC) and boiling
> points below 100ºF (37.8ºC); (2) Class IB liquids -- those liquids
> that have flash points below 73ºF (22.8ºC) and boiling points at or
> above 100ºF (37.8ºC); (3) Class IC liquids -- those liquids that have
> flash points at or above 73ºF (22.8ºC), but below 100ºF (37.8ºC).*

**Comments to Data Collected by ERG Background Information Docket,**

**November 14, 2005**

**C1** -- The State of New York Department of Environmental Conservation
developed a method to identify equipment at an area source in order to
have a clear understanding of each type of machine within the state.
This identification spontaneously was accepted throughout the United
States by individual states, Air Resource Divisions, and the drycleaning
industry. The identification known as Generation 1 thru 4, allows an
immediate understanding for many different versions of PCE equipment
currently in operation. It was the basis for the rule making within the
state. The ERG memorandum of background information documents mentions
this NY Standard of Identification only when it is describing a
particular type machine, but not before using a complex description. The
ERG report makes reference only in comparison to explain the research
presented in the report.

As an example*;* in the ERG's memorandum, "Industry Trends of Major and
Area Source Drycleaners", November 10, 2005.

Section 2.0 ERG: *"Most new drycleaning machines have secondary controls
(dry to dry close loop.... also known as 4^th^ generation).*

ERG's failure to first make this identification aspect its main source
of reference when reporting to EPA lends to confusion, which then
results in a proposal that does not reflect current technology, nor can
it clearly identify operating equipment.

The NIOSH Standard HC18, also allows for a clear explanation of
operating equipment; however, is not mentioned in ERG report.

Why this is important: In the case of New York State, as well as Clean
Air Act, by defining particular industry processes and in these terms,
allows for rule making compliance to contain real guidance as to its
intent. With the lack of generation terminology, IMC finds the proposal
misleading in its explanation of PCE facilities

The proposal, Section I, Background, B. "What are PCE drycleaning
facilities?" states; *"drycleaning machines can be classified into two
types: transfer and dry to dry"*. Public comments by non-industry
stakeholders will not understand that this classification is extremely
vague. Additionally, state and local authorities having jurisdiction
(AHJ) for compliance, will not be able to determine control systems on
equipment when NESHAP has not identified all equipment and systems
currently in operation.

IMC strongly disagrees with the proposal's description of machine
classification, and object to its obscurity in clearly identifying for
the public this aspect.

IMC questions the validity in this rule making.

**C1.2 --**ERG's Memorandum *"Control and Alternative Technologies"*,
May 16, 2005

It is apparent that the researcher's focus to submit favorable data for
alternative technology,

as opposed to reporting on current highest level of emission control of
PCE machines. See ERG's Memorandum, Section 3.1 "Carbon Adsorber", and

Section 7.0. "Reference" ^1^

ERG failed to capture data on this more recent information regarding
carbon adsorbers. Instead they submitted data from 1988, neglecting more
current and readily available data. In fact in the same memorandum,
Section 3.0 "Emission Control of Drying Cycle", confusion is created in
the understanding of their research and how it applies to PCE risk
reduction.

***[1988 Data]{.underline}***

The German rule for halogenated solvent (perc) came into effect in 1988
^1a^. It was revised in 1990 for adjustments and alignment to the intent
of that rule. Any reference to carbon adsorption on equipment at that
time can not be deemed up to date with today's understanding of carbon
adsorption standards. Current data is available with regards to carbon
adsorption and certified by laboratories^2^. that are authorized by New
York State Department of Conservation and California Air Resources Board
who have tested the efficiency of carbon adsorbers on current operating
systems.

ERG makes subtle references in different memorandums with regards to
carbon adsorbers; however, the assembly of data and the way in which it
is presented raises considerable concern to their intent

IMC strongly disagrees with ERG's data collection on carbon adsorbers,
and object to the proposal's obscurity in clearly identifying more
current data for the public in this aspect.

IMC questions the validity in this rule making.

*\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*

***References:***

^1^ *Sieber J. H. "Reduction of solvent vapor emissions in the
drycleaning plants the present state of technology, November 7,
1988*^1a^*.*

*^2^ New York State DEC, Sec. 232.12 of 6NYCRR - approved independent
equipment testing organization, Environmental Risk Management
International, Inc., April 12, 2002*

**C1.3 --** ERG's Memorandum, *"Control and Alternative Technologies"*,
May 16, 2005

Section 1.0 **Introductions,** *"The primary source of PCE emissions*
*are from the dry cycle and fugitive emissions from drycleaning
equipment, (including equipment used to recycle PCE and dispose of PCE -
laden waste). In older machines, the majority of emissions from the
drying cycle are vented outside the building. In new non-vented
machines, dryer emissions are released when the door is opened to remove
garments. [Fugitive emissions can also come from leaking valves, seals,
and loading and storage of PCE".]{.underline}*

The proposal, Section I.B., states *["Currently, the largest source of
emission from drycleaning is from equipment leaks, which come from
leaking valves, seals, and loading and unloading of
garments"]{.underline}*.

These two statements are another example as described in C1 and C1.2,
the need for a clear identification of operating systems. ERG's
explanation of "*older machines vented/newer machines non-vented"* is
quite vague and misleading.

However, it is evident that the research by ERG reported in this
memorandum for emission and fugitive emissions, was published in the
proposal, out of context of its original meaning. This aspect of changed
context is evident throughout the NESHAP proposal when compared to ERG's
research memorandum.

IMC strongly disagrees with the proposal's claim to largest source of
emission, and object to its obscurity in clearly identifying emissions
to the public by using ERG's research findings out of context.

IMC questions the validity in this rule making.

**C1.4** -- ERG's Memorandum, *"Control and Alternative Technology"*,
May 16, 2005

Section 2.2, depicts a "typical" drycleaning machine with secondary
emission control in diagram, and then in a step by step process stage of
its operation. The process stage reflects a heating (drying) stage at 12
minutes, a cool down stage at 12 minutes, and a secondary control 2
minutes.

This process stage was not referenced to its source, within ERG
reference Section 7.0. Section 2.2 goes on to explain the condenser,
temperature and the differences if this cycle is processed in "older
Machines" vs. "new machines".

Again, here in the reporting of ERG to EPA, the identification of the
machine type and configurations erodes. But more importantly, ERG
produces a cycle time for a "typical" drycleaning machine which IMC is
unaware of within the industry. And, if this cycle does exist, it is not
"typical".

Actual real data could be found at New York State DEC Machine
Certification^1^, and the laboratory analyses of each machine within the
country, or at least within the State of New York.

With no reference of where ERG collected its data for this section,
coupled with its description of "typical" machine with emission
controls, the total cycle time reflected in this report to EPA is 39 to
45 minutes.

This aspect is truly troubling since the proposal is required by CAA 112
(f)(2)(A) to take into consideration cost, energy, safety...... to
protect public health.

The real certified cycle time of a "typical" (accepted industry
terminology - 4^th^ generation machine) is 55 to 60 minutes. The
difference on time is found in the drying, cool down, and adsorption
phase, normally referred to as the second half of a cycle.

IMC calculates all area sources (28,000 drycleaners) as follows:

28,000 drycleaners

x 8 cycles (average of typical drycleaning shops)

[x 6 days/week]{.underline}

1,344,000 cycles/week x 40lbs of garments/cycle = 53,760,000lbs of
garments

69,888,000 cycles/year x 40lbs of garments/cycle = 2,795,520,000lbs of
garments processed

Then, if IMC uses ERG's calculation of kilowatt consumption of typical
machines, adding the 15 lost minutes for their data, consumption of
electric, steam, and water is changed. Any data generated to reflect
cost in any option within the proposal is incorrect.

Therefore, the research done in ERG's report to EPA to formulate the
proposal in accordance with CAA 112 is inaccurate.

In footnote utility cost of ERG Memorandum of "Cost of Regulatory
Options for Area Source Perchloroethylene Dry Cleaning Facilities",
November 11, 2005, reference is made as follows. "*The increase in
energy cost for secondary control can be approximate by factory based on
the length of cycle time using 60 minutes and 45 minutes."* This
footnote needs explanation to its usefulness in calculating utility
cost. Again here IMC directs the EPA's attention to the lost 15 minutes
of cycle time in ERG's Table 2.1, Process Stages Cycle.

IMC strongly disagrees with the proposal's claim to reducing risk by
evaluating associated cost, and objects to its obscurity in clearly
identifying true cost for the public in this aspect.

IMC questions the validity in this rule making.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

^1^ ERMI reports regarding machine certification on file publicly @
www.nysdec.state.ny.us

**C1.5 --**ERG's Memorandum, *"Control and Alternative Technologies"*,
May 16, 2006.

As already commented in IMC's Section C1, C1.2, C1.3, and C1.4, the same
memorandum of ERG, Section 2.2 -- Table 2.1, and then in 3.4 Application
of Control Technology, ERG attempts to explain the various equipment
configurations.

The assembly of this data, and the method in which ERG reported it to
EPA, could be a reason why the proposal asks 33 times within the
document for public comment.

With respect to the enormous amount of data available to ERG and EPA
from sourcing, such as industry stakeholders, as well as individual
State Air Resources Division (New York and California), this section, as
well as the other mentioned sections, are not accurate in its
explanation of control technology.

CAA 112 is a document that focuses on reduction of emissions of
hazardous air pollutants. The drycleaning industry, and its proven
control technology, addresses this aspect. ERG research failed to
effectively identify it, but more importantly, the context of the
proposal, possibly could lead to misinterpretation of proven control
technology.

IMC strongly disagrees with the proposal's claim to reducing risk by
options of additional control technology, and objects to its obscurity
in clearly identifying this control technology for the public.

IMC questions the validity in this rule making.

**C1.6** -- ERG 's Memorandum, *"Control and Alternative Technology",*
May 16, 2005.

Section 4.1, 4.2, 4.2.1, and 4.2.2 will be addressed in our explanation
of control technology later in this comment package. IMC is compelled to
set aside most of ERG's report in this category since it does not
reflect true and accurate data. While these mentioned sections are
crucial to the reduction of PCE emissions, these aspects must be
explained in true technical respect of what can be accomplished. This is
not emphasized in ERG's report, or the proposal.

IMC strongly disagrees with the proposal's claim to control technology,
and objects to its obscurity in clearly identifying actual data for the
public in this aspect.

IMC questions the validity in this rule making.

**C1.7** --ERG's Memorandum, *"Control and Alternative Technology"*, May
16, 2005.

Section 4.3 **Closed Direct-Coupled Delivery** -- IMC agrees with
"Closed Loop" delivery of PCE for all area sources. However, presently
there exist two non-interchangeable methods of this delivery system. One
manufactured by Dow, and the other by Vulcan Chemicals. While the
modification of installing these connectors to an existing PCE machine
does happen, IMC has seen this after market modification installed
incorrectly. Guidance is required in this aspect. For new PCE machines
this add-on equipment presents a different challenge since these
connectors are not interchangeable. Manufacturers of machines, and/or
vendors, do not have prior knowledge to suppliers of solvent of a given
area source. The ERG report only references Dow.

The proposal fails to mentions "Closed Direct -- Coupled Delivery", nor
does it address the fact that this delivery system should be mandated to
be universal. By making a standard specification of Closed Couple
Delivery of PCE, the fittings can be installed on all new machines and
existing machines correctly. Installations of fittings can then be
carried out per manufacturer's specifications of the universal fittings
by the manufacturer of the equipment. Dow and Vulcan need to comment on
these closed loop delivery systems.

The proposal makes reference to vapor room to protect emission from
escaping to co-residential dwelling; however, it skips a crucial aspect
of solvent delivery and a need to capture fugitive emissions when
filling a PCE machine.

If the research by ERG is to identify real control technology, it failed
to present this small aspect effectively, which can account for emission
of PCE and fugitive emissions of PCE by non-interchangeable coupling
delivery system. There exists a need to require in all states,
regardless of the PCE control technology, or age of equipment, a
vaporless solvent delivery system. A universal interchangeable coupling
is essential to ensure this system is effective.

IMC strongly disagrees with the proposal's options to reduce residual
risk in the absence of identifying emission sources, and objects to its
obscurity in clearly identifying fugitive emission source for the public
in this aspect.

IMC questions the validity in this rule making.

**C1.8 --**ERG's Memorandum, *"Control and Alternative Technology"*, May
16, 2005

Section 4.4 **Waste Water** - In ERG's explanation of how waste water is
generated, and its method to handle it, ERG provides an opinion to
reducing emissions of PCE as follows.

*"As a safeguard against evaporation, a surge of water containing highly
concentrated PCE that has broken through the carbon filter, some
equipment suppliers offer a relatively inexpensive switch (less than
\$100.00) that shuts off the evaporation if a high concentration of PCE
is present in the effluent of the first filter".*

ERG then adds; *"If waste water was treated in this fashion, and then
sewered instead of* *evaporated, the air emissions reduction would be
even greater".* *(A disadvantage of pre-treating waste water with carbon
filters is that it generates hazardous waste from used filters.)*

IMC has a great concern with ERG's opinion to reducing air emission by
instead sewering waste water. CAA112 does not imply reduction in HAP to
happen by ignoring articles set forth in Clean Water Act. ERG's
statement also compels us to think the proposal is reckless in its
attempt to reduce residual risk. While we found no reference within the
proposal regarding this statement, we argue that the ERG's report as
part of the public docket can lead to a misinterpretation by the reader.

IMC strongly disagrees with the proposal's intent to reduce air
emissions by methods outside the scope of CAA, and objects to its
obscurity in clearly identifying control technology for the public in
this aspect.

IMC questions the validity in this rule making.

**C1.9** -- ERG's Memorandum, *"Control and Alternative Technologies"*,
May 16, 2005

Section 4.6 **Room Enclosure -** New York State Department of
Environment 6NYCRR§232.6(a)(1) clearly identifies a vapor barrier, not
room enclosure, and defines it as; vapor barriers. "*Vapor barriers
must, at a minimum, enclose the drycleaning equipment......"*

New York requirements are quite different than that of California Air
Resources requirements for vapor barrier. California has several
different version of vapor barrier, and it depends on the Compliance
Division of California at a given area source, to the guidance of
construction. Some of California's enclosures are partial, while some
are total enclosure. The real difference can be found within the two
rules for containment of emissions within the individual states.

Either way, ERG states in 4.6 that an enclosure of approximate 12' x 10'
x 10' constructions costs according to some New York City drycleaners,
is approximately \$15,000.00. This part is accurate when IMC reflects on
that particular compliance portion for New York Drycleaners in "Co-Mix"
facilities, and vapor barrier requirements and its compliance deadline
date.

Further more, figures of New York Drycleaners should include cost of
construction increases from compliance deadline to present. Construction
cost for residential home improvement, as well as commercial
improvements have increased 15% to 20%^1^ since full compliance deadline
of vapor barriers in New York State.

However, in ERG Memorandum of "Cost of NESHAP Revision for New
Co-Residential PCE Drycleaning Facilities -- October 5, 2005 and Cost of
Regulatory Options for Area Source PCE Drycleaning Facilities, November
11, 2005", ERG gives an estimate of \$7,950.00 based on a contractor who
builds enclosures in San Francisco.

Ideally, without guidance on construction to the proposal's option of
room enclosures in co-residential area sources, coupled with reporting
of two different costs and lack of up to date construction figures, IMC
finds that any cost calculation methodology of reducing residual risk by
using data of ERG is inaccurate.

IMC will elaborate further within this comment package the intended
purpose of vapor barrier, and their usefulness and feasibility in the
absence of Building Code Standards.

IMC strongly disagrees with the proposal's claims in related costs for
reducing residual risk, especially in co-residential area sources, and
objects to its obscurity in clearly identifying the true costs to the
public in this aspect.

IMC questions the validity in this rule making.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

^1^ Reference: U.S. Dept. of Labor Bureau of Labor Statistics, Producer
Price Index Materials & Components for construction values Between 2001
to Present.

**C1.10** -- ERG's Memorandum, *"Control and Alternative Technologies"*,
May 16, 2006

Section 4.7 **Work Practices -** ERG's vague description of work
practices, and available data regarding the importance of this aspect,
again demonstrates their research less favorable to the existing control
technology within the industry.

Both New York State and California have training programs designed to
educate the shop owners to the proper methods of handling PCE, its
operating equipment and procedures within a scope of proactive guidance
structure. Proper and uniform education to the area sources, as well as
AHJ, can only lead to reduced risk factors. This performance based
program is simple and cost effective with regards to reducing emissions.

With PCE and emission, a focus on work practices, should be an essential
aspect of the NESHAP to reduce risk. However, this proposal lacks this
focus within its options.

Proper work practice for PCE is warranted. However, proper work
practiced for alternatives proves to be even more critical.

1.  Hydrocarbon, Cyclic Siloxanes, and Glycol Ethers have flashpoints

2.  Liquid Carbon Dioxide is in [critical pressure]{.underline} (850
    psi) and considered a [pollutant^1^]{.underline}

3.  Water for wet-cleaning is a natural resource, whose waste is drained
    to sewers

IMC strongly disagrees with the proposal's methods of reducing risk
factions by suggesting alternatives to PCE and vaguely identifying real
control technology for PCE. We object to its obscurity in identification
of emission reduction methods together with control technology for the
public in this aspect.

IMC questions the validity in this rule making.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

^1^ Pollution prevention activity in Ohio under PPIS Grant by U.S. EPA,
October 2001

**C1.11 --**ERG's Memorandum, *"Control and Alternative Technologies"*,
May 16, 2005

C1.11 (a) Section 5.1 -- **[Synthetic Hydrocarbons]{.underline}** - ERG
states operation cost for using synthetic hydrocarbon (HCS) is about the
same as using PCE. *"Cycle time is approximately 60 to 65 minutes
compared to 40 to 45 minutes of machine using PCE."* As already
mentioned in our comment C1.4, ERG does not pin down a realistic cycle
time for process. ERG in their table 5.1., references SCAQMD, 2002, as
to its source for figures. That amended rule 1421, has been subject to a
great deal of criticism for its data. Therefore, calculation in
associated cost of proposal options is flawed.

ERG Table 5.1 shows *environmental* effects as "*little to no HAP and
minimal VOC"*.

1.  What is the definition of "Little to no HAP"?

2.  What is the definition "Minimal VOC"?

The State of California has a VOC rule^1^ for drycleaning. VOC,
regardless of maximum or minimal within the State of California, is in
fact a VOC^2^.

In the same SCAQMD, 2002 Report October 2002 Statement of Finding,
Statement of Overriding Consideration & Mitigation Monitoring Plan, and
the potency increase in VOC emissions from all affected drycleaning
facilities, in the worse case scenario, would exceed SCAQMD's daily VOC
significance thresholds.

That same report includes a statement of overriding considerations which
target considerations such as CAA requirements of EPA to industry
adverse air quality impacts resulting from a decrease of emissions of
one pollutant by increasing the emission of a different pollutant --
modification or offset (CAA112).

Considering that all States must be in compliance with Federal mandated
standard for HAP & VOC, IMC expects that a large net increase of area
sources moving to alternatives, such as Synthetic Hydrocarbons, will
indeed trigger a new rule making process for the industry, State by
State.

The State of New York regards hydrocarbon as minimal HAP^3^ (less than ½
of 1%). New York also has a rule^4^ for this minimum HAP; however, has
not yet enforced it upon those area source drycleaners using
hydrocarbon.

C1.11 (b) Section 5.2 -- **[Cyclic Siloxanes]{.underline}**

ERG fails to mention the operating cost of this alternative, or its cost
per gallon (presently \$28.00/gallon), or its license fee accurately
(\$2500.00/machine/location/year).

ERG Table 5.2 depicts *environmental* *effects* as no residual risks are
associated with its use. This in itself is speculative and should have
not been included in their memorandum report to EPA. Scientific data is
incomplete and still not available to the public for evaluation. EPA has
yet to rule on data submitted by these interested industry stakeholders.

C1.11 (b)(1) - ERG reports that conversions of existing PCE machine to
GreenEarth has met the approval of several municipal fire departments.

National Fire Protection Association, NFPA 32 committee has spent a
considerable amount of time with conversion, modification, and
remanufacturing of existing Class IV machines (non-combustible) to Class
III machines (combustible). A complete data package is available to the
public, which states that the committee is unaware of any "approved"
conversion, modification or remanufacturing of equipment. If in fact
this is being done, it is outside the scope of the guidance standards
set forth in NFPA 32.

***More comments will follow later on in this comment packet regarding
conversions.***

C1.11 (c) Section 5.5 - **[Carbon Dioxide]{.underline}**

ERG states that a CO2 process is similar to the PCE process, but the
equipment is much different because of high pressure needed for liquid
CO2.

ERG's explanation of CO2 gas to liquid process is an aspect that should
raise considerable questions. Beyond the safe environmental aspects
which support CO2 drycleaning technology, (IMC disputed) it should be
noted that CO2 use in process, from a liquid to a gas, reclaimed,
filtered, distilled, and pumped in a continuous drycleaning process, is
questionable in regards to safety. Marketers of these systems usually
claim CO2 drycleaning is as safe as CO2 canister storage at a McDonald's
restaurant used for soft drinks.

Presently there exist no safety standards, which IMC is aware of, to
address these particular machines. While indeed there are many
pressurized code standards by AMSE, ANSI, NFPA and others, these
standards are for storage and use at stationary sources or in mobile
(transport and handling) sources of pressurized liquids which are
non-combustible, non-flammable, non-toxic, and [not
process]{.underline}. NFPA 32 recently made additions to the 2006
Edition in review by the Standard Code Council addressing CO2
Drycleaning. These additions did not address critical dangers involved.
It is the committee's intent to draw more stakeholders of CO2 technology
in this standards guidance process.

Most AHJ's and EPA's do not have the experience or knowledge to
understand the critical dangers of installing a CO2 drycleaning machine,
in a typical occupancy especially when the experience throughout the
world with this process is virtually non-existent.

However, there is an enormous amount of data addressing structure
damage, injury as well as fatalities in cases of extreme over-pressure
shock waves by explosion. The 750 psi pressure of CO2 drycleaning
equipment is capable of shock wave incidents, in particularly, with a
mechanical failure. For dwelling and structures, sever damage with frame
collapse and massive destruction, would result from 10-12 psi incident
pressure. These over-pressure shock waves are sudden and spontaneously
rapid, unlike shock waves produced by hurricanes or earthquakes. IMC is
not implying that a CO2 drycleaning process experienced this problem;
IMC draws attention to alternative to PCE advocated by NESHAP, as well
as SCAQMD, which may have a serious consequence in regards to lack of
experience, lack of code standards, and lack of technical expertise
while leaving the industry to address these challenges.

Therefore, IMC can not accept a reduction in residual risk, advocated by
EPA, with an alternative technology such as CO2, as a method to comply
with CAA 112. Furthermore, the cost ERG describes for the liquid CO2 at
\$.25/lb is inaccurate. The \$.25/lb figure^5^ is if the area source was
to have its own CO2 storage tank outside the building, which is
questionable in regards to compliance, with most local occupancy codes.

ERG states "nominal amounts" (10lbs) of CO2 gas is vented to the
atmosphere each cycle. This data is not proven nor has it been measured
by independent report for EPA.

In March of 2001, President Bush reversed his decision to seek cuts in
emission of CO2 the main source of global warming. In a letter to Sen.
Chuck Hagel (Neb.), the President cited a Department of Energy report
which determined regulation of CO2 emissions to be too costly.

CO2 used for drycleaning is captured by stack emissions of other
industry in order to reduce CO2 in the atmosphere. If CO2 is captured
then released by drycleaning equipment at the end of each cycle; does
the drycleaner becomes the stationary source of emission of CO2?

The CAA Section 302(g) says that an air pollutant is any physical,
chemical, biological, or radioactive......substance or matter which is
emitted into or otherwise, enters the ambient air.

In Section 103(g) Congress explicitly included emission of CO2 from
fossil fuel power plants in a list of air pollutants prevention
programs^6^. This section calls for improvements in non-regulatory
strategies and technologies for preventing or reducing multiple air
pollutants, including carbon dioxide from stationary sources. While this
section does not require EPA to regulate CO2, IMC considers that a
modification of an existing area source from PCE to CO2 alternatives is
an emission offset (a.k.a tradeoff). However, for NESHAP to suggest CO2
modification, it would be governed by CAA to present it along with a
review of BACT Standard, or under a New Source Review for New or
Modified Facilities.

Furthermore, the United States has committed under the Senate ratified
Rio Climate Treaty to adopt programs aimed at returning United States
carbon dioxide emissions to 1990 levels.

SCAQMD uses the rational of eliminating emissions of PCE sources by
switching to CO2 process and thereby justifying an emission offset
methodology. The staff reported that CO2 captured by other industry
stack emissions is recycled, therefore the net emission of CO2 in the
region from CO2 area source drycleaners does not add to its total
inventory. IMC expects the EPA rational to be the same as SCAQMD, and if
this is the case, IMC has two concerns.

1.  Why does EPA seek ways to capture CO2 stack emissions from one
    industry, then advocate releasing CO2 in small amounts at area
    sources of a different industry?

2.  Why hasn't EPA allowed captured PCE of recycled hazardous waste from
    hazardous waste treatment, storage and disposal companies who handle
    drycleaning PCE waste, and used the captured PCE to reduce figures
    of estimated tonnage emitted by all sources?

With no pressure safety standard for CO2 drycleaning equipment, coupled
with very little experience as a viable alternative to PCE drycleaning,
this aspect can not be recognized as a method of reducing risk of major
or area source drycleaners, especially as it is classified as a
pollutant.

C1.11(d) -- **Wet Cleaning**

Along with solvent drycleaning machines, IMC manufactures machines that
use only water for "dryclean only" fabrics. IMC does not agree with ERG
's reference to lower operating cost, because of saving on solvent,
hazardous waste disposal and electricity with respect to wet cleaning.

Wet Cleaning is a very particular process which dictates real challenges
to operators. While enormous strides have been made in this type of
process, IMC is sure much more time is required to make it a realistic
approach. It should be noted that the experience in metal cleaning, and
industrial uniform cleaning, (aqueous cleaning and Wet Cleaning
respectively) have both demonstrated environmental challenges once the
area source processes, were modified from PCE or solvent to water.

This modification for metal cleaning resulted in damage to components
being processed. As an example, General Motors Corp. used an aqueous
cleaning method for their engine division. The degreasing process by
water caused component deterioration of the engine which resulted in
early failure of manufactured components. Waste water used for
degreasing also presented a challenge for General Motors, and for the
most part, General Motors has switched to sand blasting components and
out sourcing solvent degreasing requirements to other companies.

Similarly, industrial uniform cleaning, using water to clean work wear
was faced with contaminated water by the pollutants/contaminants coming
off the garments in the wash process.

The State of Massachusetts had mandated several of these facilities to
incorporate waste water treatment equipment on premise. Local, municipal
sewer treatment facilities, do not have the ability to handle additional
waste water from area sources if those sources were to switch from a
closed-loop drycleaning system to a wet cleaning system. A wet cleaning
system sewers all water regardless of what is in it. Water is a natural
and precious resource protected by Articles of the Clean Water Act. A
typical 40lb capacity wet cleaning system uses approximately 50 gallons
of water/cycle.

IMC calculates water sewered as:

28,000 drycleaners

x 8 cycles/day

[x 6 days/week]{.underline}

1,344,000 cycles/week

[x 50 gallons/cycle]{.underline}

67,200,000 gallon of water sewered/week

[x 50 weeks]{.underline}

3,360,000,000 gallons of water sewered/year

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

^1^State of California South Coast Air Management District, Rule 1102,
amended August, 2000.

^2^State of California Air Resources Board, Method 422, Determination of
Volatile Organic compound in Emissions for Stating Sources, Amended
December 13, 1991

^3^Conversation with Mr. Stan Byer New York State DEC Air Resources
Division (2002)

^4^6NYCRR, Part 201

^5^ S. Langiulli Conversation with Jack Belluscio Formally of Global
Technologies 3/2006

^6^ Pollution Prevention Activities in Ohio Under Grant By US EPA,
October 2001

C1.11(E) - Summary of This Comment Section:

IMC is concerned in the manner ERG reported Control Technology and
Process Improvement in this memorandum, and we question its accuracy of
data. If ERG assembled this particular memorandum differently, their
reporting of a PCE process from Section 2.0 up to 4.7, and from Section
6.1 to 6.4, the reader could have a better chance of analyzing and
evaluating its data. Unfortunately, this is not the case, and reported
information became mis-interrupted within this proposal.

This memorandum claims within its introduction that its content supports
an EPA review of NESHAP for PCE drycleaning, September 22, 1993.

*"If warranted, revision to the drycleaning NESHAP will be made to
reflect improvements in drycleaning technology that will reduce PCE
emission."* Under CAA112(f)(B), EPA is required to report to congress on
technology and commercial available methods and cost of reducing risk.
The NESHAP proposal I.B., *"What are PCE drycleaning facilities?"* uses
data generated within the ERG, May 16, 2005 memorandum. That identifies
for the public *"The primary source of PCE emissions from dry-to-dry
machines are the dry cycle and fugitive emissions......"*. The proposal
takes this statement directly from the ERG report. However, within the
same paragraph of the proposal, it claims *"Currently the largest*
*sources of emissions from drycleaning are from equipment leaks....."*.
(See IMC's comment C1.3)

EPA, as required by CAA(d)(6), must review technology base standards and
revise them as necessary taking in to account development in
[practices]{.underline}, p[rocess]{.underline}, and [control
technology]{.underline}. -- EPA NESHAP proposal falls short of meeting
this requirement.

The NESHAP proposal scope identifies for the public within its content,
that major and area source PCE equipment have emissions at every part of
its operating system, including its accessory equipment. Therefore, it
is required by CAA112(f)(2) to calculate risk posed or potential risk,
to determine if MACT standards protect public health.

If IMC accepts (which it does not), that the proposal concludes all
equipment at major and area sources have emissions, regardless of the
proposal's identification to the type of process equipment. Then any
modifications (alternatives) to PCE to reduce or eliminate emission
could be deemed to have the same result in emissions. CAA112 (g)
modifications (1) offset *"\... change in the method of operations of a
major source which results in a greater than de minimis increase in
actual emissions of a hazardous air pollutant shall [not]{.underline} be
considered....."*

The proposal, and its research by ERG, does not determine that any
option within its source category, can meet the requirements of this
section.

The proposal claims in (75894) *"there are also some uncertainties about
whether the waste from alternative solvent systems would be classified
as hazardous."*

C1.12 -- ERG's Memorandum, *"Existing Non-Regulatory Programs of
Drycleaning",* July 17, 2003

ERG reflects in this memorandum, programs by state and local agencies
incentives towards pollution prevention. The underlying importance to
this document is the essence in which IMC is compelled to submit this
entire comment package to EPA.

The identified state programs presented by ERG detail a local regulatory
modification towards PCE emission reduction within their respective
regions that can in effect be counterproductive.

ERG categorized these programs to 4 groups. IMC will focus on one
mentioned part.

***"Publicity to create demand for PCE alternatives from outside the
drycleaning industry."***

This category, which IMC will also include later on in our summary, can
be characterized as unfair government intervention, which then can lead
to total disenchantment of its projected performance within the
industry.

Throughout this ERG Memorandum there is evidence of extreme examples
between small business proactive assistance and total condemnation of
small business activities.

As an example, IMC directs attention to state programs of New York,
Wisconsin, Virginia, Pennsylvania, Michigan, and Maryland. Here these
states embrace small businesses affected by regulatory compliance issues
by providing grants, low interest loans, training and education
programs. These programs are a proactive approach to balance and
preserving environmental and health factors by which the effected small
businesses have connection with.

In a previous memorandum, ERG reports that New York has adopted the most
stringent rules regarding PCE drycleaners. While this is a true
statement, it should also be considered that New York State's role
focused on a performance based standard of using PCE effectively and
safely. The work accomplished by New York State Department of
Environmental Conservation, together with key industry stakeholders, is
a testament on how regulation and compliance benefits both participants.

However, when comparing programs, such as those in California, Oregon,
and North Carolina, incentives are centered on forcing the small
businesses to switch to an alternative deemed by the regulatory agencies
as suitable replacement of PCE. To drive that message to the area
sources, the regulatory agencies will campaign publicly, through media
and property owners, forcing choice to alternatives.

The small business owner has no reasonable option but to accept this
alternative and the small amount of incentive money attached to it. In a
coalition activist group's report about the drycleaning industry, it was
noted that the shop owners are mainly minorities, are misinformed to the
environmental impacts and health risks associated with the use of PCE.

IMC naturally does not agree with this assessment; however, it is
evidence of how regulatory maneuver can persuade shop owners to switch
to alternative through media.

That same coalition group references public government officials such as
NYC former public advocate, and Ms. Judith Schreiber, Chief Scientist,
NY Attorney General's Environmental Protection Bureau.

It is a manipulative practice of government, which the industry can not
compete with. As the draft of this comment is in process, the Washington
Post, March 20, 2006 headlines Judith Schreiber, *"For that just-pressed
look, another price to pay"*. The emotionally charges article towards
public health for residential dwelling near to a drycleaner is a perfect
example how to build a wall between the problem and its solution.

C1.13 -- ERG's Memorandum, *"Major Source Emissions and Cost
Estimator"*,

March 7, 2005.

Section 2.3 **Baseline Emission Estimator -** ERG estimated the amount
of PCE in a spent cartridge filter by basing it on figures of the filter
vendors. This vendor is not referenced with ERG, Section 6 of the same
memorandum.

With respect to the type of work processed in the major source category,
gloves, leather, oily adsorbent, etc. using data of the filter vendor,
can not be deemed accurate as to the amount of PCE in spent filters
especially when configuring mass balance baseline emission estimators.

ERG could have used data of South Coast Air Quality Management District
(SCAQMD), mass balance study of 19 area source facilities (2002), since
this data was conducted by actual testing. Still even with the actual
data of SCAQMD, a margin of error should apply based on the nature of
the major source application of cartridge filters within this respective
process.

Additionally, ERG could have dropped out 2 of the identified major
sources since they have shut down operations, ALAC and ACME Sponge. All
equipment has been removed, ERG made IMC aware of ALAC in e-mail 6/2005.

This compelling news should have been reflected within the proposal to
the public.

C1.14

Due to a deadline of public comment period, IMC is forced to suspend the
balance of its comments to data collect by Eastern Resource Group.

However, as already requested in our opening comment page, IMC requests
an oral presentation in order to complete its comments.

C2 -- Conclusion of ERG's Research

This section has been omitted due to comment deadline.

C3 - Performance of PCE Machines

C3.0 - For this section IMC will use only recognized industry
terminology adopted by New York State DEC, Rule Part 232 for machine
configuration -- Generation 1 to 4.

We remind the EPA that presently there exists no official definition of
any generation type above 4; however, there exists assumptions of a
proposed next level of control. Therefore, IMC will explain machines
starting with Generation 3 in detail and move in its description to the
highest level of control currently in use in the industry on a global
level.

C3.1 - A third generation machine can have differences in its
construction and component arrangement, which can produce different
fugitive emissions at the loading and unloading (drum), as well as other
areas on the machine itself.

Depending on the manufacturer of the machine, as well as its
manufactured date, and the area it is installed, fugitive emissions will
vary.

[Manufacturing:]{.underline} Currently, all new machines manufactured
for use with PCE are imported into the USA. Manufacturing divisions of
drycleaning machine are located in Italy, Germany, France, Spain, China,
Japan, and Korea.

It is the requirement of the manufacturing divisions to incorporate
control technology on equipment they manufacture for all countries in
which they export to.

While not all countries have identical rules and standards, the general
intent is the same -- reduce or eliminate emissions, protect the
operator, the work place, and the environment. And it is this aspect
that manufacturers have and continued to demonstrate efficiency in
reducing risk of emissions by co-joining individual country requirements
and directives.

It is indeed a capitalistic approach for assisting environmental
regulatory concerns.

[Manufacturing Date:]{.underline} In this case, the date of
manufacturing would play an important role to the above mentioned part,
since a rule or directive of an area (Germany or California) will
dictate the configuration of equipment at that effective date. Case in
point, the NESHAP 45ºF rule, produced machines on a global level to
incorporate that component, while outside the USA, this 45ºF rule has
not been adopted by any other directive. Nevertheless, it is a component
of PCE machines globally.

[Area of Installation:]{.underline} In the USA local ordinances, such as
building departments, fire departments, and health officials, contain
code standard additions to a machine installation area (a.k.a. --
control area). A permit planner may request additional ventilation,
exhausting or containments, which he/she deems necessary according to
life safety codes, and other locally adopted code standards. Usually
these occupancy based additions, are required by the AHJ who is focused
on issues important to his role in the permit approval process.
Unfortunately, it sometimes produces a counter effect on the expected
emissions of the equipment.

C3.1(b) Ideally, a third generation machine should be a prerequisite to
a fourth generation, but in many cases it is not.

A third generation machine manufactured as new today is a dry-to-dry
machine, whose recovery section (dryer) incorporates a refrigerated heat
pump (condensing coil) and cold refrigeration coil (evaporator coil),
plus a steam assist coil, where as washing and drying, and reduction
(cool down) phases happen in a closed-loop non-venting process.

Today's third generation machine finishes a full cycle of washing and
drying and reduction at the same moment a fourth generation machine
would. The only difference in the fourth generation is the addition of
equipment which can effectively reduce the fugitive emissions points at
the drum, button trap, and lint filters prior to machine being
unloaded - closed circuit to open circuit.

Drycleaning emission control is not similar to an automobile emission
control, where in that case, a catalytic converter traps emission to get
re-burned. Rather, the third generation machines uses the arrangement of
components identical to a fourth generation with a maximum effectiveness
to reclaim (capture) solvent from the load by vaporizing solvent in
garments with a heated air flow produced by the recovery section,
condensing the solvent-laden air stream by the recovery section to the
point where it is no longer effective to continue the process.

![](media/image1.jpeg){width="5.740972222222222in"
height="4.1722222222222225in"}

See Table C2-1(b) -- *Attachment 1 - Evaporation Curve*

This table depicts the evaporation curve of PCE in a third and fourth
generation machines:

The curve of evaporation depicts solvent recovery and determines that
additional circulation of the heated air, regardless of temperature or
time, have no reflection on additional solvent recovery.

All other solvent handling components on board a third generation
machine can be found on second generation and first generation, as well
as fourth generation machines. The other solvent handling components are
90% of the overall operating equipment of a drycleaning process. These
components are commonly referred to as the purification of liquid -
distillation, filtration, pumps, liquid coolers, additive injection
systems, and process tanks.

If PCE did not have risks associated with its use, then the 90% of
equipment required to keep the solvent in pure conditions for the next
cycle, would not be needed. However, this is not the case. Nor is it the
case with any other liquid used within the drycleaning industry.

Today's alternative solvent machines, hydrocarbon, silicone, glycol
ethers, and CO2 are essentially third generation machine configurations.
That is a direct result of an industry that can identify, practice, and
produce equipment and process with a sharp focus on health hazardous and
environmental risk factors.

Q.  Can a third generation machine become a fourth?

```{=html}
<!-- -->
```
A.  Technically yes, but there exists a large number of factors which
    will influence

> the result of such a modification.

Q.  Can a third generation machine become an alternative solvent
    machine?

```{=html}
<!-- -->
```
A.  The immediate answer is NO. Presently all alternatives, with the
    exception of super critical liquid CO2 and wet cleaning, are
    combustible. A manufacturer who produces a machine for a specific
    fire rated class of liquid, (PCE = Class IV), has testing and
    labeling that machine by certified testing laboratories (UL, ETL,
    FM) for that specific class. Additional product liability policy
    would not support a change in classification of a manufacturer's
    machine without the manufacturer's involvement in such a
    modification. And as stated in our previous comment C1.11(b), this
    practice of converting equipment, and claims of "approval" by local
    AHJ should be **prohibited** if it is done **with** the guidance
    standards set forth in NFPA 32, and with the original manufacturer's
    testing laboratories re-labeling of the equipment for its new use
    with a different class liquid.

Ideally, if an existing PCE machine has fugitive emission by leaks at
valves and seals, changing the class of liquids, within that machine,
can only result in a fugitive emission of a combustible vapor.

C3.2 - A fourth generation, New York State Certified machine, is a third
generation machine with the addition of a regenerable by hot air,
non-vented carbon adsorbers capable of reducing PCE emissions in the
access parts \<300 ppm.

New York State Department of Environmental Conservation did not require
components such as closed automatic distiller clean out systems,
internal lint wash down, spin filtration, hot air distiller drying
system, closed loop coupled solvent delivery. However, NYS DEC did give
guidance to area sources that they should include these fugitive
emission reducing components as part of the new machine they were
purchasing to comply with the rule's intent. Most likely, these
components were not part of the original rule due to the absence of
manufacturing representation at the time of their rule making. Because
of this absence, IMC pledged itself to be present and part of any ruling
from that point on -- the essence of its comments here.

C3.2 (b) - German Legislation: After the Second Emission Control Act
monitored the concentration in drycleaning machines and metal degreasing
machine, it published data submitted to the German Parliament by
Deutscher Bundestay, Druskache 12/8260. This data charts the reduction
of PCE consumption over the 15 years of the adopted rule. It depicts
1986 PCE consumption of 45,000tons/year down to a remarkable
4,800tons/year without any ban of PCE, and only a less than 10% of the
shop using other alternative solvents. The Second Emission Control Act,
mandates a monitoring system (analyzer) on board fourth generation
equipment to ensure that the equipment will reach 2gm^3^/290 ppm prior
to the access hatches being opened. This type of control technology
addresses the "process technology aspect" and pins down the uncertainty
of possible emission escaping from an otherwise normally functioning
equipment. Operators of PCE machines in Germany indirectly can tract the
ongoing performance of their equipment based on the analyzer data. This
means that typical cycles in a particular machine that demonstrate cycle
time of approximately 50 to 55 minutes routinely, while the analyzer
will continuously posts values digitally/or printed with time and date,
each cycles grams or ppm of values. If typical cycle times increases
over a period of days or weeks, and values posted by the analyzer are
nearing its maximum allowability, operators are conditioned to believe
that a machinery problem is occurring.

As with our cars in the State of New York, as well as many other States,
we are accustomed to yearly emission inspections. These inspections
ensure that the car does not emit above the maximum allowability
emission standards. However, during the 12 months of using the car, an
operator could never determine if and when the car is over these limits.
Most drivers would not notice the higher fuel consumption or even the
stream of smoke in the exhaust. The same is true for the drycleaning
operator. Weekly checking by certain devices, plus calculations taken at
the drum, are indicators of fugitive emissions. However, an analyzing
device connected to the equipment, which can be interfaced with the
equipment's primary and secondary control, is the maximum achievable
control technology currently in operation with a sound and documented
success.

With approximately 2200 machines in operation using PCE in Germany, and
more than 6000 industry test by regulatory compliance officials,
documentation to the success of PCE process equipment is proven and
ongoing. It should be noted that these analyzation devices are exclusive
to PCE and designed to disregard fluorochloro-hydrocarbon (FCHC) and
propyl alcohol -- components usually found in additives (surfactants) in
a drycleaning machine. IMC can produce more information to EPA upon
request, and can demonstrate its performance as well. IMC also reminds
EPA that monitors, analyzers and instruments manufactured exclusive for
the drycleaning and metal clean industry come from several manufacturers
who at this period have suspended their production of these instruments
due to no interest other than the original German ordinance. (No current
market exists.)

IMC does not feel this is a determent, we only want to address the
immediate available of exclusive instruments is questionable. A list of
manufacturers who have designed and produced these instruments can also
be provided to the EPA upon request. SCAQMD does not have any data or
experience with the instruments which were exclusively manufactured for
the drycleaning equipment industry, and therefore their data would not
reflect the proven tract record of these instruments.

IMC demonstrated this control technology to authorities of New York
State DEC after the Rule 232 was adopted. We request EPA to contact New
York State DEC for comments on this control's performance.

C3.2 (c) - ERG has questioned IMC on several points regarding analyzers.
They specifically asked if an analyzer can decrease the consumption of
PCE in fourth generation machines. The answer is no. It does however act
as the audit of each cycle performed and can be programmed through
software to prevent operator errors which then would produce less
consumption of PCE and decrease dramatically fugitive emissions.
Indirectly the answer becomes yes.

This aspect was recognized by the German legislation rule makers back in
1991. The rule makers, together with industry stake holders, developed a
method of working with the solvent, PCE, in a way which addresses all
the [known aspects]{.underline} of it. This cooperation was inclusive of
environmental, health, economics, performance, and labor skills and the
public's well being. The results, and the success of the rule, are well
documented.

C3.3 - 45º F Maximum Air Temperature in Exhaust Air Stream of Cool Down

This requirement mandated by NESHAP 1993, adopted by states, and in some
cases such as Rhode Island, was reduced to 40ºF. It was designed to
ensure a refrigerated drying system to achieve maximum efficiency. At
the time it was adopted, the majority of equipment at area sources was
first and second generation equipment. IMC still questions the reasoning
during that period to the effectiveness of a standard such as this.

Nevertheless, IMC suggests the 45ºF rule at the Federal EPA level needs
to be set aside for third and fourth generation equipment as well as
alternative solvent machines. IMC can demonstrate, and document, the
increase of fugitive emissions at the loading door (drum), while
conforming to this requirement and demonstrating that using this
temperature compliance on any other non-PCE (alternative) equipment can
result in compromising safety in combustible atmospheres.

As an example of rules without substantiation; IMC questioned a Rhode
Island compliance inspector to why he wanted 40ºF instead of 45ºF. His
reply was that 40ºF must be better to reduce fugitive emissions, and the
machine has the ability to achieve the lower temperature, therefore 40ºF
is better.

In California a staff personnel working on the proposed Rule Amendments
of 1102, for VOC stated that carbon adsorption and 45ºF would be
required for alternative cleaning processes. IMC responded verbally that
Hydrocarbon is not adsorbed by activated vapor phase carbon beds, and
45ºF is a dangerous requirement if certain and particular controls of
combustion safety equipment are not respected .

The final Rule 1102 adopted 45ºF; however, did not mandate carbon
adsorbers.

IMC has determined by its own experience that most third generation
machines, manufactured as third generation machines, regardless of the
time it was manufactured, and regardless of who manufactured it,
incorporates two refrigeration pressure control gauges. High and low
pressure gauges. These gauges are vital to the performance of the drying
section of the equipment. Whereby every individual manufacturer has a
set value of high and low pressure settings according to his equipment,
which then produces optimum performance of the refrigeration section,
therefore maximizes the drying and reduction efficiency.

If pressure settings are incorrect the curve of evaporation (which is
fixed by expected performance designs) changes. As stated earlier, a
third generation machine is essentially a fourth generation without
absorber. So this means if pressure settings are incorrect, the third
generation machine will have a high output of fugitive emission at the
drum, and a fourth generation would demonstrate to be the same. An
analyzer would prevent the fugitive emissions since it can detect that
system is not at peak performance, and thereby protect the carbon bed
from crisis saturation.

Q.  What are the influences that change refrigeration pressure?

```{=html}
<!-- -->
```
A.  Many factors have influence but usually, and the most common, is
    cooling water temperature and its flow to the refrigeration unit.

99% of all operating machines with a refrigeration group have water
cooling circulation to keep a stabilized pressure of refrigeration.
Unlike our home air conditioning units that use ambient air to maintain
refrigeration pressure, a drycleaning machine requires precise and equal
balance of its high pressure and low pressure to attain optimum
temperature. Every machine regardless of who manufactured, has water
control valves, adjustable by operators in order to respect the correct
operating pressure. These controls usually are adjusted two times per
year -- warmest climate conditions -- coldest climate conditions.

If machines are set in accordance with their manufacturer's
recommendations of high and low pressure, the operator will be able to
determine during the drying phase if their equipment is at peak
performance, and in this case by ignoring the 45ºF rule.

Presently, complying with 45ºF in the exhaust air at the end of the
cycle; the operator has no way of determining if in fact the machine
effectively traveled the curve of evaporation. IMC has heard of
compliance officials instructing operator to add more time to reduction
phase (cool down) of their equipment in order to reach 45ºF. And in some
cases, this has constituted an additional 10 minutes to cycle. IMC is
not imply that a longer cycle time is not warranted in some situations,
but under some circumstances, adding 10 minutes to a reduction phase in
certain machines would result in a two fold fugitive emission problem
produced by a compliance rule.

Q.  What happens in the case of 45ºF precedence?

```{=html}
<!-- -->
```
A.  First the cycle extents beyond the known curve allowing for a
    reduction of temperature in the garments. The garments now become an
    ideal medium to capture vapors.

With each pass of circulated solvent-laden air, the PCE gets re-adsorbed
on the fabric of the load. Fabric adsorbs quicker than activated carbon.
One only has to hold a cotton towel over a boiling pot of water to prove
this point.

For this reason the Second Ordinance of Emission Control Act in Germany
mandates that the temperature of garment in a PCE machine, as well as
alternative solvent machine, can not drop below 35ºF (95ºF) at the end
of the cycle. They determined and proved this by the analyzer on board
tracking the curve of evaporation.

The second scenario that results for extended reduction phase is ice
formation on the cold (evaporation) coil of refrigeration. Since the
vapor inside the recovery section of a drycleaning machine is PCE and
relative humidity from the fabric, the water condensation starts to form
ice, blocking air flow passage through the coils. With a reduced air
flow, the refrigeration units are powerful enough to freeze over and
create a total blockage. With each consecutive load the freeze area
increases while the recovery decreases. If the operator is focused on
the 45ºF rule, he in turn extends the cool down phase attempting to
arrive at 45ºF. And with no air flow, his chances of arriving at 45ºF
are useless.

By setting aside 45ºF for proper high and low pressure reading, an
operator can determine everyday with a two second glance at these gauges
if he is traveling the curve of evaporation correctly. This in turn
allows for the dry control devices on all machines to work correctly
regardless of the fabric of the load; cotton, silk, heavy leather, etc.
And, the operator can override the machine during a time when he has the
chance to adjust operating process.

C3.4 -- IMC has noticed that NESHAP 93, as well as the proposed NESHAP,
does not require weighing loads prior to loading the machine. In ERG's
reporting, it was stated that due to the burden for operators to weigh
each load; this NESHAP would not make a requirement. Weighting every
load and recording on a log, is important regardless of the machine or
area source category.

Every manufacturer has a rated capacity as well as a visual indication
of load factor. These factors are based on a mixed variety of fabric
content. This means that if a machine has a 40 lb dry weight load
capacity, the operator can not load the machine with 40 lbs of dry
weight feather (down) coats. In this case he would underload
considerably. Major sources who routinely clean articles such as work
gloves, already know their respective load factors regardless of what
the machine is rated for. However, in an area source drycleaner, his
loads are always mixed since the work is retail clothing. The fast way
to unexpected fugitive emissions is the disregard load factors.

IMC strongly urges this aspect to be a requirement as it is in NYS DEC
Rule 232.

C3.5 -- [Automatic Still Clean Out Systems]{.underline}

As mentioned in the ERG report of a NIOSH study. This system developed
for the German rule, comes to the USA by international manufacturers'
vested interest in assisting in the reduction of fugitive emission,
without a rule to require it.

Essentially, the distiller is the mechanism of purification of the
liquid PCE. Its final product is a residual mud which contains PCE as
part of its content. Opening the distiller door to scrap out the mud
allows for fugitive emission to escape. However, if the door remains
closed and mud is extracted by means of an internal device capable of
scraping the surface, mud is then pulled or pushed to an exit port of
the distiller, via hard pipe, and pumped directly into a sealed
hazardous waste container. Air within the container is displaced back to
a closed machine distiller. Air displacement is critical in any closed
system. Without the correct air displacement, the automatic still clean
out system is useless -- fugitive emissions will escape.

A sealed hazardous waste container is also a factor. If an analyzer was
attached to a machine and a fugitive emission increase over the maximum
allowability value, the analyzer would in this case alarm and post this
value with time and date.

It is also important to note that fourth generation machine generate a
lower volume of distiller waste but a much higher concentration of PCE
within the waste. However, considering that higher PCE value is
contained in a sealed waste stream, it is considered controlled. If the
NESHAP and area regulatory rules enforce less PCE in waste streams,
fugitive emissions and waste water will increase dramatically.

IMC can elaborate on this aspect if requested.

C3.6 -- Drying Sensors (A.K.A. Dry Control Device)

We return to the curve of evaporation, and show that in third and fourth
generation machines, the curve is identical. It is also known that with
proper settings of a refrigerated recovery section, the curve must
follow a path in direct relation to time and temperature based on its
[load]{.underline} factor.

If it takes 15 minutes to arrive at the top of the curve, then it is
that factor of time which is programmed into the machine cycle control
system (micro-processor or card program reader). This is commonly
referred to as primary drying time. Once a machine has reached that
portion of the drying cycle, the machine will ask the drying sensor to
take over. The sensor then checks if additional drying time is required.
There are several different types of a dry sensor. Nevertheless they are
standard components of equipment, which determine success of the drying
cycle. They are commonly referred to as secondary drying control.

When the dry control device proves drying complete, the machine will
then switch back to additional drying by time. This is done for several
reasons.

1.  In the case dry control has malfunctioned and allows the machine to
    skip this important aspect, the additional time after dry control
    becomes the redundant safety factor. It is reflected in the curve.

2.  It was recognized by the rule makers in Germany, as well as New
    York, that if the machine drying process is functioning properly,
    the dry control step would determine quickly that drying is
    successful and the additional time after dry control

> (3 to 5 minutes depending on the rule), would not be a hindrance for
> the extension to a cycle process. Mandatory drying time after dry
> control is a redundant safety feature to ensure fugitive emissions are
> indeed reduced to this lowest level.
>
> IMC agrees with Germany and New York State DEC in their process for
> PCE, as well as alternatives.
>
> In Germany the rule allows for either a machine dry control, or a
> analyzer that includes the capability of tracking the drying
> evaporation curve during the cycle. In a case such as this, the
> analyzer becomes a dry control device and the machine can delete this
> component from its on board equipment. Analyzers that incorporate dry
> tracking capabilities are naturally higher in cost. It is not
> mandatory in Germany to have this function on the analyzer, it is an
> option.

C3.7 -- Carbon Adsorption Cycle Lock Out

All fourth generation machines, manufactured as fourth generation
machines, complete the evaporation curve to end the drying and reduction
phase. Prior to the access hatches opening, the drum, button trap and
lint filters must be evacuated of the residual PCE by means of a carbon
adsorber.

Depending on the manufacturer, the recovery section is isolated, either
completely or partially of the drum, while the residue PCE in the air of
the drum is circulated to an activated vapor phase carbon bed. Table 2-1
depicts this adsorption step. The time of this step varies from machine
to machine by manufacturer and model. Time is approximated, 4 minutes
for this step. During this step the operator is prevented from opening
the hatches by locks and door switches.

The carbon will effectively drop the concentration in the drum to \<300
ppm based on the success of the drying and reduction stage.

If for the moment we return to our comment of 45ºF, it now become clear
that if the garment temperature is reduced to a point where
solvent-laden air can be re-adsorbed by cold fabric, the step of carbon
adsorption would result in levels of residual PCE in the drum above 300
ppm.

In a machine with an analyzer as in Germany, the device will track the
value of PCE in the drum as well as at the carbon bed. This ensures that
the value is achieved in the drum, and the PCE has not broken through
the carbon with the air returning to the drum. For example, at
completion of the adsorbtion phase the level of PCE at the drum is high,
while the level of PCE at the carbon is low, a determination can be made
that either a valve has malfunctioned or a lint filter between the drum
and carbon has not been cleaned. 9 out of 10 times it is the latter.
Therefore, an analyzer is without doubt the on board compliance officer.

Without the analyzer, the operator can effectively determine successful
cycles within acceptable fugitive emissions, if he can read the vital
signs of his system. 45ºF is not one of these vital signs.

All carbon adsorbers in the proposed NESHAP rule should conform to the
rules set forth in New York State DEC Part 232.

C3.8 -- Vapor Barriers

As previously discussed in our Section C1.9, vapor barriers or vapor
rooms, are parts of rules in New York, California and Germany.

\- New York State DEC required a vapor barrier at a minimum to enclosing
the drycleaning machine for all area sources that are attached to a
co-residential or co-mixed businesses -- stand alone facilities are
exempt.

\- California's rule requires only certain occupancies to have a vapor
barrier, and then it is further divided to total or partial type
barriers for the drycleaning machine.

\- Germany's rule required vapor barriers in shops that have
co-residential type occupancy.

There exist sharp differences between each rule and its conformity to
intent of the rule.

\- New York State DEC required that a vapor barrier must have walls,
floors and ceilings covered with PCE impervious material (list of
construction material approved on file at New York State DEC), with
closing doors, intake and exhaust air exchange of the controlled area.

\- California requires walls and ceilings only with air exchanges within
the control area to meet the permit of that area source's requirements.

\- Germany allows for either the machine, or the entire equipment area,
to have control based on the shop owner's choice. Either way the rule
requires a vapor block between the shop and adjoining walls, with air
exchange of the control area. The rule has approved construction barrier
material that can be used.

Each individual rule serves the purpose of preventing fugitive emissions
to migrate into areas where otherwise is not expected, and to protect
humans occupants of opposing dwellings from PCE inhalation.

In both New York and California, the requirement of vapor rooms proved
somewhat difficult for compliance since these rooms were required
without a construction detailed plan. While each rule does incorporate
approved material, neither New York nor California as IMC believes it
address the construction aspect with state and local officials of the
building departments and fire departments. This aspect is vital in terms
of improvements to commercial occupancy. If local building departments
and fire departments were involved in construction guidelines, do they
in fact embrace the room's intended purpose?

Drycleaning shops come in many different shapes and sizes and many of
them are in pre-existing, non-conforming settings due to the period in
which the occupancy became a drycleaning shop vs. the period in which
local code standards were adopted. Vapor barriers/rooms present a
tremendous challenge for all effected area sources.

Subsequently, if NESHAP rules on vapor barriers/rooms for co-residential
facilities, IMC fears individual states will interpret risk factor
differently and require the same in all area sources which would create
even a larger problem complying with the occupancy code standards
adopted locally.

Case in point, local code officials whose townships have adopted
International Fire Code frequently request rooms commonly referred to as
control areas in new drycleaning shops around the drycleaning machine,
if the shop has water washing equipment as part of his equipment package
in the permit application. IFC requirement is brought down from
International Building Code (IBC), and is not solvent class specific.
Its requirement was based on a history of laundry fires and therefore a
drycleaning shop that uses a washing machine and dryer in addition to
his drycleaning process, presents to the AHJ a similar hazard scenario.
While IMC does not agree with this code standard in IFC, IMC draws
attention to the fact that vapor barriers/rooms compliance with NESHAP,
New York and California are quite different from IFC. Each standard
presents a different type of control of hazard.

If it is not addressed through an organized effort of code officials,
air quality officials, and industry stake holders, the value of any
barrier, or room, is compromised.

There are many opinions of control technology of a machine. The evidence
of that brings us here today, NESHAP, SCAQMD, as well as New York State
DEC, do not address local building code standards.

Vapor barriers, such as those in New York, are a construction nightmare.

Therefore, IMC suggests allowing the committee of NFPA 32 to set the
guideline standards of barriers to where it is required and to the
methods of which it should be done. In this way all stake holders'
benefit from its intended purpose. This is indeed the way Germany has
accomplished this aspect for their rule. In fact, Germany in many cases
allows for a construction material impervious to PCE that is painted
and/or wallpapered on the walls, floors and ceilings to make a
successful barrier. With proper guidance, by the NFPA 32 committee,
individual states who may decide to require vapor barriers will be able
to have at their resources approved materials and details at a national
level to successfully accomplish its intended task. A construction
situation done in this way would produce companies who can manufacture
product that focus exclusively on the obstacles.

-   Space

-   Egress

-   Fire safety

-   Vapor tightness

-   Functionability

-   Uniformity

-   Economics

We can not be ignorant to a rule's intent and a rule can not be ignorant
to its implications.

C3.9 -- Work Practices

Beyond all other things that can produce a reduction in fugitive
emissions, the education level to the process is vital, and this does
not only apply to PCE.

New York State DEC recognized this point. They mandated in their rule a
certification process with training and re-certification, that empowered
the operator to be able to detect problems; but more importantly, make
them aware of the importance of their environmental management
responsibility. IMC allowed New York State DEC to use of its facility
for training purposes. 16 hour classroom training with a maximum
operation of 40 participants per class. IMC was present during these
classes, and witness the impact it had on New York drycleaning
operators. Every participant walked away with a clear understanding of
their process, its equipment, and their responsibility to protect the
health of the public.

IMC seeks this type of environmental management throughout the industry
as a means to co-exist with the public it serves. The importance of this
training can then be extended to all types of drycleaning processes
(alternative) because each has an environmental responsible aspect
beyond the things that are known.

IMC suggest this aspect of education of process, support the views of
New York State DEC, and possibly allow New York State DEC to lay the
ground work of its methods of instituting it.

C4 -- Alternatives to PCE

One of the largest misconceptions is that all countries including the
USA thought that Hydrocarbon alternative was a direct result of
Germany's rule for PCE. This is not the case. Germany, prior to the rule
1988, had approximately 4800 drycleaning shops. Almost 20% of those
shops used fluorocarbons (a solvent Freon based). These solvents were
phased out due to their contribution to ozone depleting greenhouse
gases.

These drycleaning shops utilizing fluorocarbons were accustomed to the
gentleness of solvent which allowed these shops to routinely cleaned
garments that require a delicate cleaning process. PCE solvents were too
aggressive for their needs. Around the same period, developments in
petroleum based, specialty chemical, were becoming more available due to
other industries complying with directives. These synthetically made
stable fluids had higher flash points, were odorless and colorless, and
proved to be a suitable alternative for those cleaners. The higher flash
point also allowed for the solvent to be handled without any special
apparatus outside the machine in ambient temperatures.

Prior to the higher flash point solvents availability, the standard
petroleum based solvents with a flash point was between 105ºF to 140ºF,
and were known to be unstable. Benzene concentrations with the lower
flash point solvents created even more challenges, since benzene is a
HAP.

In the USA Hydrocarbon solvents became available in and around 1994 and
accepted by the market as a suitable replacement by 1997. Today it is
the most recognized and desired alternative if an area source chooses to
purchase a non-PCE machine. A Hydrocarbon machine is a third generation
machine, with all its solvent purification equipment, designed to
protect against combustion. Ideally they do not emit combustible vapors
during normal operation. As opposed to a transfer petroleum machine that
emits combustible vapors into the work room during normal operations.

Manufacturers who produce third and fourth generation PCE machines, and
who additional produce alternative machines for the combustion liquid
group, do so in accordance with all the emission reducing components of
the PCE machines. They delete certain components that can create hazards
such as carbon adsorption, and add equipment in support of the safety
mechanisms to prevent combustion.

Code standards of NFPA, Uniform Fire Code (UFC), and Western Fire Chiefs
(WFC) at that time did not have performance standards of the equipment
within the guidelines directives. Presently the most up to date standard
in the country is NPFA 32, which incorporated the occupancy, the class
of solvent, and the type of process (machine) with its safety features
as a standard for all code officials. Code officials have been inundated
by permits for drycleaning shops switching to alternative solvents --
Class IV to Class III.

IMC has seen many times how state air regulations towards PCE
drycleaners pushed compliance from one department to another (air
quality to fire/building) without allowing these opposing authorities to
review the rule changes, as in the case of vapor barriers. The industry
is left to address this situation on their own and without the
assistance of the Division of Air who mandated change. Consequently,
local AHJ conform in their townships to either IFC Standards or NFPA
Standards. The difficulty is that these two standards are equal in one
respect only, their intent of safety, but differ in how to achieve it.
IFC is a **prescriptive** code base standard while NFPA is a
**performance** based code standard.

All machines built today for use with Class III solvents are
**performance** based construction. It is indeed a huge problem when an
area AHJ refuses to permit a shop unless the shop adheres to the
**prescriptive** aspect of the IFC Code. In many cases sprinklers and
control rooms are required, as well as ventilation which IMC has
considered as an impediment of the machine's safety.

NESHAP has not identified this challenging and associated cost in the
move to alternatives and IMC fears the consequences of this oversight
cost, is not the only challenge. IMC is not implying that safety should
be set aside for cost reasons. On the contrary, we direct every ones
attention to the point that IMC has spent a considerable amount of time
addressing it and educating local AHJ.

During 2005 IMC, along with a committee person of NFPA and a Senior
Chief Engineer of Chevron Phillips, gave a seminar to the local
fire/hazmat officials of Santa Clara, California. The inspectors and
compliance officers were stunned to see what a drycleaning machine using
Class III solvent was composed of.

NESHAP, EPA, and most State and local Air Resource Divisions have a lot
of experience with drycleaners and their shops. Code officials of
building and fires departments [do not]{.underline} have the same
experience. In fact, in many cases they have none.

IMC speaks for the industry in this respect and ask EPA for help. EPA
can not expect to make a rule with a focus on moving 28,000 area sources
to a combustible solvent without adhering to the article of Clean Air
Act that stipulates a situation such as this. Additionally, as
maintained in our Section C.11(c)(d)., the same holds true for the
non-combustible alternatives as well. At the very least, NESHAP should
set aside the requirements of alternative machines, subpart JJJ of
40CFR, Part 60 Standards of Performance of Petroleum Drycleaners. This
rule is useless, outdated and ridiculous to comply with since it was
designed for transfer equipment and is covered in layers of dust!

Currently IMC has been asked to conform with this subpart in four
different states. We refuse to comply on the basis of the rule's
protocol of equipment. Nevertheless, NESHAP's proposed reductions of
residual risk factors using alternatives as a risk factor reduction
estimate has failed to research the obstacles that lay in its path.

No State agency as generated adequate data in this direction.

Rational of Our Comments

C5

IMC (I) did not address every request for comments the proposal has
asked. Instead I opted to research all reports and data the proposal was
formed on. I spent a considerable amount of time reviewing and
commenting to the ERG Background Information Docket, to the point that I
am out of time to submit comments. Therefore, I never completed the
task. What I found most compelling of the ERG data is ERG's personnel,
Mike Heiney, Eric Goehl, and Jennifer O'Neil, never had prior knowledge
of the industry and its history. They first had to learn from it, then
collect its data, and report to EPA to form the NESHAP Proposal. Their
reporting time frame, approximately 2 years.

It is apparent the focus is on substantiating risk and a need to review
NESHAP, but as stated earlier, EPA is required to report all available
control technology and processes.

My criticisms of their data are not based on the quality of their
report, rather it is pointing out that we are an industry whose business
activities dictate rules and regulations. And the industry has
consistently demonstrated its willingness to assist in guidance rules
that contain a balanced equally shared responsibility. My personal
attack of the data is based mainly on misinterpretation discovered in
that data, which then results in a proposal that reflects negativity on
the industry itself.

Beyond rules there lies a spirit of the individuals these rules serve,
and if that spirit is crushed, the industry as well as the public
suffers.

NESHAP represents the minimum standards which can then be the starting
point by each state to either maintain the minimum or increase it.

I am well aware that in certain urban areas and geographical regions,
there exist a need to enhance the minimum standards beyond the NESHAP,
but it is the NESHAP and it's reporting to the public, which set the
stage for reckless and counterproductive comments by government figures.
I can believe that this happens because a person, a group or entity, is
passionate about the duty they have in society. But at the same point,
the drycleaning industry is at a disadvantage when their reckless and
senseless words reach the media. Imagine if you, or your family, were
publicly labeled by a government representative as the cause to human
suffering.

The drycleaning industry is not the tobacco industry, nor is it a
corporate conglomerate network of publicly held companies with billions
of dollars. We are the drycleaner, the neighborhood local drycleaner,
who lives in the same community and sometimes in the same building. We
are family owned and operated, from the manufacturing level of
equipment, all the way down to the drycleaning shop. We are a vital part
of society that provides a necessity to every ones life. We the
drycleaner provide the means which society teaches their child to do
well in school and get an education, to get a good job and raise a
family, apply themselves, and in that respect to look clean, neat and
well groomed - because that is the society we live in.

We provide germ free clean seats on airlines, we provide low cost home
insurance rates by restoring the public personal items ravaged by fire,
water and smoke. We provide the means to preserve family memories, such
as weddings, bar mitzvahs, and anniversaries.

We are no different than the American farmer who is vital to society in
the work he accomplishes. He is embraced and supported in all ways and
his spirit is preserved. Regardless of how hard he works, he works for a
passion of his role in society, and is proud to be a contributor to it.
We provide for our own family and put our children through school, most
time without the financial assistants of State or Federal funds.

We provide clean work wear such as gloves and overalls which protect
other workers in society, as well as reducing waste stream in landfills.
We provide methods of adsorbing cutting oils from the floors of
production plants in order to reduce land filling of contaminated clay
particles. We provide clean costumes for Disney characters so our
children (as well as ourselves) can enjoy a fun family vacation. We
provide our government officials with clean and professionally pressed
suits, and we provide our armed service with the honor to wear a clean
uniform. Our fire fighters, our law enforcement personnel, all rely on
our performance. We reduce landfill by providing reusable wipes, we
provide leather tanning and process the use of the hides of cattle which
feed society. We provide clean blankets for the patients in our
hospitals and clothe the underprivileged with garments that were not
picked-up at our shops.

Every business transaction takes two parties, a buyer and a seller. The
definition of a perfect deal is each participant walks away happy.

Here's an idea, why don't we together try to make that perfect deal by
incorporating all the things that satisfy both sides.

Naturally, this is a challenge, but keep in mind we are the farmers of
"garment textile care" whose spirit is strong when the world is not
pointing a gun to its head.

IMC request a postponement in this rule making process in order to
assist EPA in complying with CAA provision set forth for a minimum
standard with maximum results.

Respectfully,

ILSA Machines Corp.

Stephen Langiulli

President

C6 -- Final Comments from ILSA Machines Corp. (IMC)

1.  IMC rejects vapor barrier/enclosures on any area source based on
    construction difficulties and lack of significant data to prove its
    usefulness. IMC suggest allowing NPFA 32 to form a standard of vapor
    barriers based on a performance application with options to its
    method of construction to comply with its original intent.

2.  IMC rejects 45ºF rule on existing and new sources. In its place, a
    rule of proper refrigeration pressure valves is recommended.

3.  IMC rejects all alternative approaches until NESHAP can address each
    alternation, in the same respect and in accordance with CAA, CWA and
    other articles of protection of the public.

4.  IMC recommends banning all transfer (first generation) PCE machines,
    effective 90 days, all source categories.

5.  IMC recommends banning all vented/non-vented (second generation) PCE
    machines, effective 90 days, area sources only.

6.  IMC recommends extending major source compliance until these sources
    can identify a reasonable method of complying with a rule. The major
    sources category is now totally 13.

7.  IMC recommends dropping all proposal options for major sources, and
    then review exclusively these individual sources since they do not
    match the category of all other sources.

8.  IMC rejects no new co-residential PCE facilities until NESHAP can
    review a report on alternatives.

> IMC feels that the NESHAP proposal will be subject to further OMB
> review under items (2) and (4) based on items in comment here within.

9.  IMC suggest training and education programs.

10. IMC suggest involving DfE into this proposal review, and allowing
    for its participation.

11. IMC request an extension by at least 1 year for a redraft of the
    proposal.

\#### END OF DOCUMENT####