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| **\"Phillips, Jennifer\" \<JPhillips@stlouisco.com\>** |
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| 04/29/2008 04:00 PM                                    |
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Hello,

This email serves as a second comment to clarify the intent of the
comment I submitted on April 8, 2008, in response to the Proposed
Changes to the revised Dry Cleaning MACT Standard. See original comment
below. My April 8, 2008 comment was not intended to adversely affect
this rulemaking. I completely agree with the proposed changes to the
Amended Dry Cleaning MACT Standard. I do not wish for this rulemaking to
be hindered based on my April 8, 2008 comment.

My comment was in regards to an additional clarification in the rule
that is associated with, albeit outside the specific scope of, this
rulemaking. However, my comment is very important for the effective
enforcement of this rule and should be addressed either now, or in a
future rulemaking. If it is not possible to address this comment now,
the St. Louis County Air Pollution Control Program, along with the
Missouri Department of Natural Resources, is requesting a written
statement from EPA stating that Section 63.323 (a)(2) of this rule
applies to transfer machines only.

Thank you,

Jennifer Phillips

Air Emission Specialist

St. Louis County Air Pollution Control Program

*74 Clarkson Wilson Ctr.*

*Chesterfield, MO 63017*

*Office: 314.615.5324*

*Fax: 314.615.0925*

**From:** Phillips, Jennifer

**Sent:** Tuesday, April 08, 2008 4:31 PM

**To:** \'a-and-r-docket@epa.gov\'; \'johnson.warren@epa.gov\'

**Cc:** Donegan, Kathrina

**Subject:** Dry Cleaner Rule Change Comment

Hello,

Please accept the comment below in response to the Proposed Changes to
the revised Dry Cleaning MACT Standard.

Jennifer Phillips

Air Emission Specialist

St. Louis County Air Pollution Control Program

*74 Clarkson Wilson Ctr.*

*Chesterfield, MO 63017*

*Office: 314.615.5324*

*Fax: 314.615.0925*

I believe the Temperature Difference Monitoring Requirement found in
63.323(a)(2), was intended to only apply to transfer units, whereas, the
current rule states that all dry-to-dry units that are not small,
existing are required to comply with this requirement. I have discussed
this issue with Gary Bertram of EPA Region VII and Bob Randolph of the
Missouri Department of Resources. Both agree with my argument below.

I\'ve found several sources that say this requirement only applies to
transfer machines. I tried going back to the initial rule on EPA\'s
website and I found a document labeled, \"Final Rule: Perchloroethylene
Dry Cleaning Facilities,\" published on 9/22/03 that states that the
temperature difference requirement between the inlet and outlet of the
refrigerated condenser only applies to transfer units (). Another place
I found this language was page II-32 of the EPA guidance found at .

In the \"Response to Significant Comments\" section of the new
requirements under Section G(2) there is discussion regarding using the
pressure requirements in lieu of the exit temperature requirement. There
is no discussion of the temperature difference requirement. In this rule
change, you are giving dry cleaners the option to use pressure gauges
instead of temperature readings, however, why would anyone want to
switch to pressure readings when they have to comply with the
temperature difference requirements anyway, which requires the
monitoring of the outlet temperature?

All of this evidence leads me to believe this section of the rule is in
error and should not apply to dry-to-dry machines.

[Rule References:]{.underline}

The definition of \"dry cleaning system\" (63.321) means a dry-to-dry
machine and its ancillary equipment or a transfer machine system and its
ancillary equipment.

The definition of \"washer\" means a machine used to clean articles by
immersing them in perchloroethylene. This includes a dry-to-dry machine
when used with a reclaimer.

63.323 (a)(2) states \"When a refrigerated condenser is used to comply
with 63.322(a)(1) or (b)(1) the owner or operator shall calculate the
difference between the temperature of the air-perchloroethylene
gas-vapor stream entering the refrigerated condenser on a washer and the
temperature of the air-perchloroethylene gas-vapor stream exiting the
refrigerated condenser on the washer weekly to determine that the
difference is greater than or equal to 20 F.\"