## United States Environmental Protection Agency

General Permit or Permit by Rule for New or Modified Minor Sources of Air Pollution in Indian Country http://www.epa.gov/air/tribal/tribalnsr.html



## Background Document: True Minor Source Petroleum Dry Cleaning Facilities General Permit and Permit by Rule

Version 1.0
Last Modified: November 1 4 , 2013



### 1. Petroleum Dry Cleaning Source Category Definition

A petroleum dry cleaning facility may consist of dry cleaning dryers, washers, filters, stills, settling tanks, and
boilers. Dry cleaning facilities normally use either petroleum solvents or perchloroethylene (PCE) as the cleaning solvents. The proposed Minor Source Petroleum Dry Cleaning General Permit/Permit by Rule only covers dry cleaning operations that are located at true New Source Review (NSR) minor sources and use petroleum
solvents.



### 2. Source Category Characterization

Dry cleaning involves the cleaning of fabrics with nonaqueous organic solvents. The dry cleaning process requires three steps: (1) washing the fabric i n solvent, (2) spinning to extract excess solvent, and (3) drying by tumbling in a hot air stream. There are two general types of cleaning fluids that are used in the industry: petroleum solvents and synthetic solvents. Petroleum solvents, such as Stoddard or 140

- F, are inexpensive combustible hydrocarbon mixtures similar to kerosene. Synthetic solvents, such as PCE, are nonflammable, but are more expensive halogenated hydrocarbons.

There are two basic types of dry cleaning machines, transfer and dry

- to

- d ry machines. Transfer machines accomplish washing and drying in separate machines. Dry cleaning as a batch process in transfer machines can result in a large amount of volatile organic compounds (VOC) or hazardous air pollutant (HAP) emissions due to

vapor ization of solvent during the transfer process. Dry

- to

- dry machines are single units that perform all of the washing, extraction, and drying operations. Since cleaning and drying take place in the same compartment of dry

- to

- dry machines, significant amount s of VOC and HAP emissions are eliminated from dry

- to

- dry machines ( AP

- 42 , Chapter 4.1

- Dry Cleaning). Most petroleum dry cleaning machines in operation today are “dry

- to

- dry” machines ( EPAs Memo 2010 )

.



### 3. State Minor Source Permit Programs

The U.S. Environmental Protection Agency (EPA) researched state government websites for general permits and permits by rule for this source category, examined them for applicability to a permit for Indian Country, and used appropriate elements in the devel opment of the documents and regulations in the general permit and permit by rule for this source category. The EPA has identified the following states and local governments that have specific NSR minor programs (such as general permit and general order) fo r dry cleaning facilities using petroleum solvent, PCE, or both: Arizona

, New Jersey

, Ohio

, Oklahoma

, Pennsylvania

, Washington , and Maricopa County in Arizona . The requirements for the state perm itting programs related to dry cleaning facilities are summarized in Attachment A. General permits from these states were chosen for examination because of characteristics they possess:

Readily available;Page 2 of 16

Clear throughput limits; and Organization of the regulations followed the typical form for federal NSR permits:

o Limitations and standards,

o Monitoring, testing, recordkeeping, and reporting requirements.

For the 7 state programs reviewed, 5 of them have solvent consumption limits and this limit ranges from 1,000 gallons/year to 6,800 gallons/year. Assuming that the VOC content of the solvents used is 8.34 lbs/gallon, these solvent consumption limits are eq uivalent to VOC emission limitations of 4.17 tons per year (tpy) to 28.4 tpy. The state permit program for Oklahoma does not have a solvent consumption limit but contains a VOC emission limitation of 100 tpy and a HAP emission limitation of less than 10 tp y for a single HAP and less than 25 tpy of all HAPs combined. Therefore, the VOC emission limitations for the programs reviewed range from 4.17 tpy to 100
tpy.

In addition to the solvent consumption limit and VOC emission limitation, the state programs i nclude the NSPS, Subpart JJJ ( Standards of Performance for Petroleum Dry Cleaners ) requirements for petroleum dry cleaning facilities and NESHAP, Subpart M ( National Perchloroethylene Air Emissi on Standards for Dry Cleaning Facilities ) requirements for PCE machines. For state permit programs in Arizona, the permits also include capacity limits for fuel combustion units, such as limiting the maximum capacity for each boiler to less than 10 MMBtu/h our.



### 4. Requirements for General Permits and Permits by Rule

4.1 Documents for General Permits and Permits by Rule

The EPA developed a standardized set of permit documents in support of a general permit and permit by rule for dry cleaning facilities. T hese consist of the following documents:

Questionnaire : Assists the facility owner or operator in determining whether they are eligible for a General Air Quality Permit or a Permit by Rule;

Request for Coverage u nder the General Air Quality Permit : Stat es the criteria for qualification, gathers information on the source, facility location, and source contact, and requests technical information on facility equipment, throughput, and attainment status;

Notification for Coverage under the Permit by Rule : States the criteria for qualification, gathers information on the source, facility location, and source contact, requests information on the facility, the facility’s potential to emit (PTE), and requests that the source certify they will comply with the requirements, which are included in the rule for dry cleaning facilities at 40 CFR 49.162 ;

Instructions : Guides the applicant in filling out the Request for Coverage under the General Air Quality Permit and a Notification of Coverage under the Permit by R ule;

General Air Quality Permit, Terms and Conditions : Contains the requirements and regulations with which the source must comply. The emission limitations, monitoring, recordkeeping and reporting requirements are in the permit, including requirements fo r sources located in nonattainment areas. (Note that all of the requirements and regulations with which the source must comply in a permit by rule are included in the rulemaking action the EPA is taking for this source category.); andPage 3 of 16

PTE Calculator spreadsheet : Allows applicants to calculate their PTE, based on owner inputs of the specific equipment present at their source, assuming continuous operation throughout the year. The PTE Calculator spreadsheet generates potential emissions, based on these inputs. The spreadsheet illustrates the correlation between equipment, raw material throughput, and emissions.

4.2 Exemption and Qualification for General Permits/Permits by Rule

Facilities applying for the proposed general permit/permit by rule must mee t the following criteria:

Must be a true NSR minor source; and Be below the emissions limitations established for the general permit/permit by rule.

New facilities with a PTE or modifications to existing facilities with an emissions increase lower than the minor NSR thresholds specified in Table 1 of Tribal NSR Rule ( 40 CFR 49.153 ) are exempt from the minor NSR program. The exemption thresholds for PM and criteria pollutants are listed in Table 1 below. Facilities applying for the proposed general permit/permit by rule may calculate their PTE using the PTE calculator provided to determine if they are exempt from the minor NSR program.

Table 1: Minor NSR Thresholds in 40 CFR 49.153
Pollutant Attainment Area Nonattainment Area Carbon Monoxide (CO) 10 tpy 5 tpy
Particulate Matter (PM) 10 tpy 5 tpy

PM 10 5 tpy 1 tpy

PM 2.5 3 tpy 0.6 tpy Sulfur Dioxide (SO 2 ) 10 tpy 5 tpy Nitrogen Oxides (NO X ) 10 tpy 5 tpy

VOC 5 tpy 2 tpy

Under current EPA policy, only true NSR minor sources qualify for the proposed general permit/permit by rule. Therefore, facilities will be required to compare their PTE to the NSR major source thresholds to determine if they qualify for the proposed general permit/permit by rule. The NSR major source threshold for attainment areas is 250 tpy of any criteria pollutant. The NSR major source thresholds for nonattainment areas are
summarized in Table 2 below:

Table 2: NSR Major Source Thresholds for Nonattainment Areas
Pollutant Nonattainment Classification NSR Major Source Threshold

Ozone Marginal 100 tpy of VOC or NO X

Moderate 100 tpy of VOC or NO X Serious 50 tpy of VOC or NO X Severe 25 tpy of VOC or NO X Extreme 10 tpy of VOC or NO X PM 10 Moderate 100 tpy

Serious 70 tpy

CO Moderate 100 tpy

Serious 50 tpy

SO 2 , NO 2 , PM 2.5 No nonattainment classification 100 tpyPage 4 of 16

If the facility’s PTE is above the NSR major source threshold of 250 tpy, or above any applicable nonattainment area thresholds listed in Table 2, then the facility does not qualify for the proposed general permit/permit by rule. The following documents are available to assist sources in the screening and application process:

Questionnaire; Request for Coverage under the General Air Quality Permit; and

Noti fication for Coverage under the Permit by Rule.

For facilities not exempt from the minor NSR program and having a PTE below the NSR major source thresholds, the facilities will further evaluate if they meet the throughput limits and operating requirements established in this general permit/permit by rule. The specific requirements for the proposed general permit/permit by rule
are discussed in Sections 4.3

, 4.4, and 4.5. The emissions associated with the throughput limits are lower than the NSR major sourc e thresholds and were derived as described below in Section 5.

4.3 Specific Permit Requirements for General Permits/Permits by Rule

The terms and conditions of the proposed general permit/permit by rule were established according to the required permit content and analyses in the Tribal Minor NSR Rule. The required permit content is listed in 40 CFR 49.155(a)

– What information must my permit include? Below we describe the basis for the permit
conditions.

40 CFR 49.155(a)(1)

– General Requirements The rule establishes general requirements that each permit must identify: the effective date of the permit; the date by which the owner/operator must commence construction in order for the permit to remain valid; the emission units subject to the permit an d their associated emission limitations; and monitoring, recordkeeping, and reporting requirements to assure compliance with the emission limitations. The proposed general permit/permit by rule contains all of this required information, except for the emis sion units subject to the permit. Because of the nature of general permits/permits by rule we believe it is more appropriate to identify the emission units covered by the general permit/permit by rule in the Approval of the Request for Coverage. The genera l permit/permit by rule incorporates the Approval of the Request for Coverage into the general permit/permit by rule. Each proposed general permit/permit by rule contains a separate section that specifically
identifies the emission limitations and standard s, monitoring and testing, recordkeeping, and reporting and notification requirements.

The General Terms and Conditions in the proposed general permit/permit by rule are a standardized set of boilerplate conditions included with general permits/permits by rule. The proposed general permit/permit by rule also contains source category

- specific terms and conditions that were developed from the NSR Rule, NSPS Subpart JJJ, and the state permit examples.

40 CFR 49.155(a)(2)

– Emission Limitations The permit mus t contain the emission limitations determined by the reviewing authority under 40 CFR 49.154(c) for each affected emissions unit. 40 CFR 49.154(c)

– How will the reviewing authority determine the emission limitations that will be required in my permit?

– i dentifies the case

- by

- case control technology review that must be used by the reviewing authority to determine the appropriate level of control. In carrying out the case

- by

case control technology review, the reviewing authority must consider the following factors:

1. Local air quality conditions;Page 5 of 16

2. Typical control technology or other emission reduction measures used by similar sources in surrounding

areas; 3. Anticipated economic growth in the area; and

4. Cost

- effective emission reduction alternatives.

In addition , the reviewing authority must require a numerical limit on the quantity, rate or concentration of emissions for each regulated NSR pollutant emitted by each affected emissions unit, for which such a limit is technically feasible. The emission limitation r equired may also be included as pollution prevention techniques, design standards, equipment standards, work practices, operational standards or any combination thereof. However, the emission limitations must assure that each affected emission unit will co mply with all requirements of 40 CFR parts 60, 61, and 63

, as well as any federal or tribal implementation plans that apply to the unit. Finally, the emission limitations required may not rely on a stack height that exceeds good engineering practice or any other dispersion technique, except as allowed by 40 CFR 51.118(b). To address the requirements for establishing emission limitations the following consideration were used for setting the limits in the general permit/permit by rule for petroleum dry cleane rs:

1. Local air quality conditions

– To address this requirement, the general permit/permit rule sets more stringent limits on solvent use for sources located in any ozone nonattainment area and additional operational requirements for sources located in ser ious severe, or extreme ozone nonattainment areas.

2. Typical control technology or other emission reduction measures used by similar sources in surrounding

areas

– For sources locating in attainment areas we looked at the control requirements specified by 4 0 CFR parts 60, 61 and 63. These regulations establish minimum technology and emission limitations that must be met nationally and also meet the requirements of 40 CFR 49.154(c)(4) to ensure compliance with parts 60, 61, and 63. For this general permit/per mit rule we considered regulations that apply to the equipment at petroleum dry cleaners:

The NSR Rule ( 40 CFR 49.155(a) ) ; Existing applicable NSPS regulations: 40 CR Part 60, Subpart JJJ , Standards of Performance for Petroleum Dry Cleaners ; and The South Coast Air Quality Management District’s rule for Dry Cleaners Using Solvent Other Than Perchloroethylene ( CA Rule 1102 ) for facilities located in ozone nonattainment areas. These regulations cover emissions from facilities that are located at a petroleum dry cleaning plant with a total manufacturer’s rated dryer capacity equal to or greater than 84 pounds

.

Review of the regulations resulted in permit conditions requiring that all petroleum dry cleaning dryers
must be solvent recovery dryers and that care must be taken to ensure equipment is operated properly and solvents are properly stored.

3. Anticipated economic growth in the area

– The Reviewing Authority may consider anticipated economic growth when determining whether coverage under the general permit/permit by rule is justifiable. Considering, however, that the general permit/permit by rule sets emission standards that are consistent with what is required for petroleum dry cleaners acro ss the country in both attainment and

non

- attainment areas, we expect that this will rarely be a factor.

4. Cost

- effective emission reduction alternatives

– The proposed general permit/permit by rule sets
emission standards that are consistent with what is required for petroleum dry cleaners across the country, based on the ozone attainment status where the source is locating. As such, the chosenPage 6 of 16

technologies are considered widely available and consideration of more cost

- effective alternatives is not

necessa ry at this time. We intend to periodically review technology costs in the future to determine when more stringent, cost

- effective technologies become widely available.

40 CFR 49.155(a)(3)

– Monitoring Requirements The proposed general permit/permit by rul e must include monitoring that is sufficient to assure compliance with the emission limitations that apply to the source. The proposed general permit/permit by rule requires regular inspection of dry cleaning dryers and maintenance.

40 CFR 49.155(a)(4)

– Recordkeeping Requirements The proposed general permit/permit by rule must include recordkeeping that is sufficient to assure compliance with the emission limitations and monitoring requirements, including certain statements listed in 40 CFR 49.155(a)(4)(i ) and (ii). In addition to the recordkeeping requirements in 40 CFR 49.155(a)(4)(i), the proposed general permit/permit by rule also requires records of required inspection and maintenance of dry cleaning equipment and quantities and types of dry cleaning solvents used.

40 CFR 49.155(a)(5)

– Reporting Requirements The proposed general permit/permit by rule includes the reporting requirements listed in 40 CFR 49.1559(a)(5)(i) and (ii) related to annual reports and reporting of deviations.

40 CFR 49.155(a )(6)

– Severability Clause The proposed general permit/permit by rule includes a severability clause to ensure the continued validity of the other portions of the permit in the event of a challenge to a portion of the permit.

40 CFR 49.155(a)(7)

– Additio nal Provisions The proposed general permit/permit by rule contains the additional provisions required for each permit. These conditions are found in the General Provisions of the proposed general permit/permit by rule.

4.4 Requirements for Sources Located in Nonattainment Areas

There are additional requirements for sources located in nonattainment areas that go beyond those found in the NSPS requirements. Since some tribes are located in ozone nonattainment areas, additional requirements to reduce/control the VOC emissions (precu rsor for ozone) from petroleum dry cleaning facilities located in ozone nonattainment areas are necessary. In order to develop the additional requirements for petroleum dry cleaning facilities in ozone nonattainment areas, the EPA has reviewed the policy a nd procedures developed by the South Coast Air Quality Management District and will include part of the requirements contained in California Air Quality Rule for Dry Cleaners Using Solvent Other Than Perchloroethylene ( CA Rule 1 102 ) into this general permit/permit by rule for petroleum dry cleaning facilities located in serious, severe, or extreme ozone nonattainment areas. These additional requirements include equipment specifications for dry cleaning system, specifications for closed

- loop machines, and leak check and repair requirements. The specific requirements are included in Attachment B of this document and in Attachment C to the general permit.Page 7 of 16

4.5 Permit by Rule Requirements

The permitting package includes a Notificatio n of Coverage under the Permit by Rule, which essentially requests that the source agree to comply with the permit by rule requirements without incorporating them into a separately issued permit. The explicit requirements for a source requesting coverage u nder a Permit by Rule are specified in the rule for petroleum dry cleaning facilities at 40 CFR 49.162.

4.6 Requirements of the Endangered Species Act and National Historic Preservation Act

Prior to seeking coverage under this general permit, sources mus t satisfactorily address the permitting requirements related to the Endangered Species Act and National Historic Preservation Act. Attached to the request for coverage documents for the petroleum dry cleaning general permit/permit by rule, the EPA provides guidance t o a s s i s t sources i n c o m pl y in g w i t h t h ese two statutes.



### 5. Emission Limitations 1 

### and Surrogate Throughput Limits

5.1 Developing the Surrogate Limits and Limitations

The EPA developed solvent consumption emissions limitations as surrogates for establishing ton per year
emissions limitations for sources in both attainment areas and nonattainment areas. The solvent consumption limits in the proposed general permit/permit by rule reflect the emission rates that are listed in Tabl e 3 for petroleum dry cleaning facilities located in ozone nonattainment and ozone attainment areas. The selected

emission rate for sources located in attainment areas is consistent with state programs. The selected emission

rate for sources located in non attainment areas is suggested by the EPA

.

Table 3: Emission Rates Used to Determine Emission Limitations for Petroleum Dry Cleaning Facilities
Pollutant
of
Concern Ozone

Nonattainment
Areas Ozone Attainment

Areas Source of Emissions

VOC 7 tpy 25 tpy Dry cleaning units and
steam boilers

Table 4 contains the throughput limits for the proposed general permit/permit by rule for petroleum dry cleaning facilities located in ozone nonattainment and ozone attainment areas that are surrogates for the ton

per year emission rates listed in Table 3 . The EPA developed the solvent consumption limits for sources in both
attainment and nonattainment areas based on (1) the emission rates in Table 3 and (2) assumptions about the equipment configuration at a typical so urce.

Table 4: Surrogate Throughput Emission Limit ations for Petroleum Dry Cleaning Facilities

Throughput Limit Ozone
Nonattainment
Areas Ozone Attainment

Areas

Cleaning Solvent Consumption 1,300 gallons/year 5,600 gallons/year

1 The definition of emission limitation used in this Background Document is the one provided in the Indian Country NSR rule (described in Section 4.3) and includes requirements established by the reviewing authority that relate to the operation of a

source, which allows for the use of production throughput limits.Page 8 of 16

5.2 Emission Limitations

Three considerations form the basis for the upper eligibility limitations for general permits and permits by rule:

1. Are there any EPA regulation

- based emission limitations?

2. What do actual emissions data from the 2008 National Emissions Inventory (NEI) 2 indicate about the size profile of the source category?

3. Where do state programs establish eligibility limits?

5.2.1 EPA Regulation

- Based Emissions Limitations

There are no specific EPA regulation

- based emissions limitations for petroleum dry cleaning facilities. In general, facilities in attainment areas with a PTE of any criteria pollutant equal or greater than 250 tpy are NSR major source. Facilities with a PTE of any criteria pollutant equal to or greater than 100 tpy or H AP emissions greater than 10 tpy for a single HAP and 25 tpy for total HAPs are subject to Title V operating permit program. However, most dry cleaning facilities have actual emissions for criteria pollutants much less than 100 tpy (see the actual

emission information listed in Table 7).

5.2.2 Analysis of NEI Data

The EPA analyzed 2008 NEI data for existing dry cleaning and laundry facilities across the U.S. to evaluate the
emission limitations established in the general permit and permit by rule. Although the NEI does not include actual emissions information for sources in Indian Country, it reflects the actual emissions from general dry cleaning and laundry operations in 50 states. In order to analyze faci lities whose emissions are similar to those for sources potentially subject to the Tribal NSR Rule, the EPA selected facilities for analysis with the North American Industry Classification System (NAICS) codes listed in Table 5. For sources with these thre e NAICS codes, the EPA selected actual emissions 3 within the ranges listed in Table 6.

Table 5: NAICS Codes Selected for Dry Cleaning and Laundry Facilities
NAICS Code Description

812320 Dry Cleaning and Laundry Services (except Coin

- Operated)

812310 Coin

- Operated Laundries and Dry Cleaners

Table 6: Emission Ranges Selected for Dry Cleaning and Laundry Facilities

Criteria Pollutants VOC

Attainment Area Min. Emissions (tpy) 5 Max. Emissions (tpy) 250

Nonattainment Area Min. Emissions (tpy) 2 Max. Emissions (tpy) 250

The 2008 NEI data does not include emissions information for total PM. The EPA analyzed the emissions ra tes
listed in Table 3 that were used to establish the surrogate solvent consumption emissions limitations and

2 For more information, go to: http://www.epa.gov/ttn/chief/net/2008inventory.html

. 3 Only point source NEI data were used for this analysis. The point source inventory does not include emissions from nonroad engines.Page 9 of 16

selected facilities with emission levels similar to the facilities potentially subject to the NSR minor program, i.e., the facilities with emissions greater than the NS R applicability thresholds in Table 1 of 40 CFR 49.153 (Tribal NSR Rule) and less than the PSD major source threshold of 250 tpy. For purposes of this analysis, facilities located in
nonattainment areas are defined as facilities located in the counties tha t are designated nonattainment for

ozone

.

With the NAICS codes listed in Table 5 and the emission ranges defined in Table 6

, the EPA identified 9 dry cleaning facilities located in attainment areas and 48 dry cleaning facilities located in nonattainment areas. In
Table 8 , the EPA is providing the number of facilities (and average VOC emissions) under the proposed emissions
limitations and above the minor source thresholds.

Table 7 : Number of Facilities and Average Emissions for Dry Cleaner Facilities

.

Criteria Pollutants (VOC) Number of Facilities

Attainment Areas
Facilities > 5 tpy and < 25 tpy 9 (100% of facilities covered)

Av erage Emissions (tpy) 9
Facilities > 25 tpy and < 250 tpy 0

Av erage Emissions (tpy) N/A

Nona ttainment Areas
Facilities > 2 tpy and < 7 tpy 37 (77% of facilities covered)

Av erage Emissions (tpy) 4
Facilities > 7 tpy and < 250 tpy 11

Av erage Emissions (tpy) 12

With the emission rate in Table 3 for this proposed general permit/permit by rule for attainment areas

, 100 % of the auto body repair and miscellaneous surface coating operations subject to the NSR minor program would fall in the range of 5 to 25 tpy with an average emissions level of 9 tpy. With the emissio n rate in Table 3 for this proposed general permit/permit by rule for non attainment areas

, 77 % of the auto body repair and miscellaneous surface coating operations subject to the NSR minor program would fall in the range of 5 to 7 tpy with an average emissions level of 4 tpy.

5.2.3 State Program Limitations

The EPA researched the similar type of permits developed by Maricopa County in Arizona and the s tates of Arizona, New Jersey, Ohio, Oklahoma, Pennsylvania, and Washington and the results are summarized in Attachment A. The VOC emission limitations for these state programs range from 4.25 to 100 tpy. Basing the permit emissions limitations on the upper VOC value of 25 tpy for attainment areas is within the range of the state permit programs reviewed.

5.3 Calculating the Throughput Limits

The EPA determined the solvent consumption emission limitations by calculating the annual usage rates that would be equivalent to the ton per year emissions rates selected in Table 3. VOC is mainly emitted from the use of cleaning solvents at dry cleaning facilities but is also emitted from combustion units (such as the boilers used to provide steam). The following assumptions are adopted for this calculation:

(1) The VOC content of all the solvents applied is assumed to be 8.34 lbs/gallon (worst case scenario);Page 10 of 16

(2) Only natural gas, propane, and butane are used in the fuel combustion units at the affected facilities;
and (3) The total heat input capacity of all the fuel combustion units at t he affected facilities is 30 MMBtu/hour.
Based on the emissions factors in AP

- 42 for combustion units, the VOC emissions from the combustion units are 1.44 tpy. This capacity limit was selected because it is consistent with the bo iler capacity limit established in the state general permit program developed by Maricopa County in Arizona (See Attachment A).

Attachment C contains example calculations showing how solvent consumption limits in Table 4 corresponds to
the VOC emission l imitations in both ozone attainment and ozone nonattainment areas as shown in Table 3.Page 11 of 16



### References:

2008 National Emission Inventory Data , U.S. Environmental Protection Agency

. http://www.epa.gov/ttn/chief/net/2008inventory.html

40 CFR 49.151

– 40 CFR 49.165, Federal Minor New Source Review (NSR) Program in Indian Country

. http://ecfr.gpoaccess.gov/cgi/t/text/text

idx?c=ecfr&sid=ffc06a883374e41e6772cd842b1ac2d4&tpl=/ecfrbrowse/Title40/40cfr49_main_02.tpl

40 CFR 60, Subpart Dc

- Standards of Performance for Small Industrial

- Commercial

- Institutional Steam Generating Units. http://ecfr.gpoaccess.gov/cgi/t/text/text

idx?c=ecfr& sid=4502b9bec7883393acc0ba9745803908&rgn=div6&view=text&node=40:6.0.1.1.1.12&idno=40

40 CFR Part 60, Subpar t JJJ

- Standards of Performance for Petroleum Dry Cleaners. http://ecfr.gpoaccess.gov/cgi/t/text/text

idx?c=ecfr&sid=a4ffb0a8d823382f497b95a61ef26817&rgn=div6&view=text&node=40:6.0.1.1.1.75&idno=40

40 CFR 63, Subpart M

- National Perchloroethylene A ir Emission Standards for Dry Cleaning Facilities. http://ecfr.gpoaccess.gov/cgi/t/text/text

idx?c=ecfr& sid=6a37e67cbe4f9c3ec15b1bf1635016be&rgn=div6&view=text&node=40:9.0.1.1.1.13&idno=40

AP 42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources. http:// www.epa.gov/ttn/chief/ap42/

U.S. Environmental Protection Agency, DRAFT

, “ Petroleum Solvent Dry Cleaning Industry Profile ,” Graham Gibson and Colin Hayes, ERG ; August 4, 2010.

South Coast Air Quality Rule 1102

- Dry Cleaners Using Solvent Other Than Perchloroethylene

. http://www.aqmd.gov/rules/reg/reg11/r1102.pdfPage 12 of 16

Attachment A

– Summary of the State Permitting Programs for Dry Cleaning Facilities

State Permit

Type Type of

Facilities
Covered Emission

Limitation VOC Containing

Materials (Solvent & Coating) Consumption
Limit Other Limitations Weblink

AZ General

Permit PCE Dry

Cleaning N/A < 2,100 gallons/year for PCE < 10 MMBtu/hour for each

boiler; and NESHAP, Subpart M

. http://www.azdeq.gov/environ/air/permits/do wnload/gndryapp.pdf

AZ

Maricop

a County General

Permit Both

Petroleum
and PCE Dry Cleaning N/A < 2,100 gallons/year of PCE
< 6,800 gallons/year of petroleum solvents Limit to dry

- to

- dry PCE machines;

< 10 MMBtu/hour for each boiler; < 36 MMBtu/hour for all boilers; < 260 hp for all emergency generators; and NESHAP, Subpart M

. http://www.maricopa.gov/aq/divisions/permit _engineering/docs/pdf/Dry%20Cleaner%20Gen eral%20Permit.pdf

NJ General

Permit Petroleum

Dry Cleaning VOC < 4.25 tpy < 1,000 gallons/year Limit to dry

- to

- dry machine; and

No PCE

. http://www.epa.ohio.gov/dapc/genpermit/dry cleaning.aspx

OH General

Permit PCE Dry

Cleaning N/A < 2,100 gallons/year of PCE Limit to dry

- to

- dry PCE machines;

and NESHAP, Subpart M

. http://www.epa.ohio.gov/dapc/genpermit/dry cleaning.aspx

OK General

Permit Both

Petroleum and PCE Dry Cleaning VOC < 100 tpy

HAP < 10/25 tpy N/A NSPS, Subpart JJJ for new units; NESHAP, Subpart M;
Not use thermal devices for control; and
No use of TCE or CFC

- 113. http://www.deq.state.ok.us/AQDnew/resource s/factsheets/dryclean.html

PA General

Permit Both

Petroleum and PCE Dry Cleaning VOC < 50 tpy

VOC < 25 tpy for
selected counties HAP < 10/25 tpy N/A NSPS, Subpart JJJ for new units. http://www.dep.state.pa.us/dep/deputate/air waste/aq/permits/gp.htm

WA General

Order PCE Dry

Cleaning N/A < 2,100 gallons for

PCE Limit to dry

- to

- dry PCE machines;

and NESHAP, Subpart M

. http://apps.ecy.wa.gov/permithandbook/perm itdetail.asp?id=116Page 13 of 16 

### Attachment B

– Petroleum Dry Cleaning Facilities

For facilities located in serious, severe, or extreme ozone nonattainment areas, the permittee shall operate and maintain the solvent dry cleaning system in accordance with the requirements specified
below and in accordance with the ma nufacturer’s recommendations:

Section 1: General Specifications

1. For any dry cleaning system that is equipped with cartridge filters containing paper or carbon or a combination thereof, the cartridge filters shall be fully drained in sealed filter housing for at least 24
hours before removal.

2. All parts of the dry cleaning system where solvent may be exposed to the atmosphere or workroom shall be kept closed at all times except when access is required for proper operation and

maintenance.

3. Wastewate r evaporators shall be operated to ensure that no liquid solvent or visible emulsion is allowed to vaporize to the atmosphere.

Section 2: Additional Specification for Closed

- Loop Machines

A closed

- loop machine means dry cleaning equipment in which washing, extraction, and drying is performed within the same single unit and which re

- circulates and recovers the solvent

- laden vapor.

4. A closed

- loop machine shall not exhaust to the atmosphere or workroom during oper ation except when the vacuum pump exhausts to maintain a continuous vacuum.

5. For any closed

- loop machine that is not equipped with a locking mechanism, the operator shall not open the door of a closed

- loop machine prior to completion of the drying cycle.

6. For any closed

- loop machine that is equipped with a locking mechanism, the operator shall not inactivate the locking mechanism and open the door of a closed

- loop machine prior to completion of the drying cycle.

Section 3: Leak Check and Repair Requirem ents

7. No less frequently than monthly, the owner or operator shall inspect the dry cleaning system for liquid and vapor leaks, including, but not limited to, the following:

a. Hose connections, unions, couplings, valves, and flanges;
b. Machine door gasket and seating of the machine cylinder;

c. Filter head gasket and seating;
d. Pumps;

e. Base tanks and storage containers;
f. Water separators;

g. Filter sludge recovery;
h. Seals and gaskets of distillation unit(s);

i. Diverter valves;Page 14 of 16

j. Saturated lint from lint trap basket;
k. Button trap lid;
l. Cartridge or other types of filters;

m. Seals, gaskets and the diverter valve of the refrigerated condenser;

n. Exhaust stream ducts;

o. Lint trap ducts; and,

p. Gaskets and ducts of the carbon adsorber.

8. To inspect for a vapor leak, the operator shall use at least one of the following techniques:

a. Soap bubble technique in accordance with the procedures in EPA Method 21, Section 4.3.3

– Alternative Screening Procedure; or
b. A non

- halogenated hydrocarbon detector; or

c. A portable hydrocarbon analyzer or an alternative method approved by the reviewing authority.

9. To inspect for a liquid leak, the operator shall visually inspect the equipment for liquid leaking in a visible mist or at the rate of more than one drop every three minutes.

10. Any liquid leak or vapor leak that has been detected by the operator shall be repaired within three (3) working days of detection. If repair parts are not available at the facility, the parts shall be ordered within two working days of dete cting such a leak and the operator shall provide written notification to the reviewing authority that explains the reason(s) for delaying the leak repair. Such repair parts shall be installed within five working days after receipt. A facility with a leak t hat has not been repaired by the end of the seventh (7th) working day after detection shall not operate the dry cleaning equipment, until the leak is repaired.Page 15 of 16 

### Attachment C Emissions Calculations for Solvent Consumption Limits

Assumptions: (1) The VOC co ntent of all the solvents applied is assumed to be 8.34 lb/gallon (worst case scenario);

(2) Only natural gas, propane, and butane are used in the fuel combustion units at the affected facilities; and

(3) The total heat input capacity of all the fuel combustion units at the affected facilities is 10 MMBtu/hour.

(1) Solvent Consumption Limit for Ozone Attainment Areas: 5,600 gallons per year (see Table 4)

VOC Emissions from Solvent Consumption = Annual Solvent Consumption Limit x VOC Content = 5,600 gallons/year x 8.34 lb/gallon x 1 ton/2

, 000 lbs = 23.35 tpy

VOC Emissions from Combustion Units = Max. Heat Capacity of the Combustion units x Emission Factor x 8,760 hours/year = 30 MMBtu/hour x (1 kgal/91.5 MMBtu) x 1 (lb/kgal) x 8,760 hours/year x 1 ton/2

, 000 lb = 1.44 tpy

(Note: Emission factor is for propane combustion, which is the worst case scenario among using NG, propane, and butane)

Total VOC Emissions from the Affected Petroleum Dry Cleaning Facility
= VOC Emissions from Solvent Consum ption + VOC Emissions from Combustion Units = 23.35 tpy + 1.44 tpy = 24.79 tpy ( < 25 tpy

– the upper VOC emission limitation for ozone attainment areas)

(2) Solvent Consumption Limit for Ozone Nonattainment Areas: 1,300 gallons per year (see Table 4)

VOC Emissions from Solvent Consumption = Annual Solvent Consumption Limit x VOC Content = 1,300 gallons/year x 8.34 lb/gallon x 1 ton/2

, 000 lbs = 5.42 tpy

VOC Emissions from Combustion Units = Max. Heat Capacity of the Combustion units x Emission Factor x 8,760 hours/year = 30 MMBtu/hour x (1 kgal/91.5 MMBtu) x 1 (lb/kgal) x 8,760 hours/year x 1 ton/2

, 000 lb = 1.44 tpyPage 16 of 16

(Note: Emission factor is for propane combustion, which is the worst case scenario among using NG, propane, and butane)

Total VOC Emissions from the Affected Petroleum Dry Cleaning Facility = VOC Emissions from Solvent Consumption + VOC Emissions from Combustion Units = 5.42 tpy + 1.44 tpy = 6.86 tpy ( < 7 tpy

– the upper VOC emission limitation for ozone nonattainment areas)