Florida Department of Environmental Protection Joe Panetta, Environmental Specialist III Air Resource Management Southwest District Office September 30, 2010 Workshop for Perchloroethylene (Perc) Dry Cleaner
Transcript
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Joe Panetta, Environmental Specialist III Air Resource
Management Southwest District Office September 30, 2010 Workshop
for Perchloroethylene (Perc) Dry Cleaner
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2 Mara Nasca Air Program Administrator Danielle D. Henry Air
Compliance Manager Cindy Falandysz Air Enforcement Manager Joe
Panetta Air Program Environmental Specialist III
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3 How Dry Cleaning was Discovered Perchloroethylene (PERC) dry
cleaning facility requirements per Rule 62-213.300(1) (a), Florida
Administrative Code, (F.A.C.) Health Effects from Perc Registration
Requirements in DEP Form No. 62- 213.300(1)(a), F.A.C. (Code of
Federal Regulation) 40CFR 63.320
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4 Southwest District Air Program has Approximately 40 Perc Dry
Cleaner Facilities that are registered with an Air General
Permit
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5 ** Additional Rules may be required by Hillsborough, Pinellas
and Sarasota Counties
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Dry Cleaning 63.321 Definitions. Dry cleaning means the process
of cleaning articles using perchloroethylene. 6
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Dry cleaning came about by accident. In 1855, Jean Baptiste
Jolly, a French dye- works owner, who noticed that his tablecloth
became cleaner after his maid spilled kerosene (paraffin) on it. He
later developed a service cleaning people's clothes in this manner,
which became known as "nettoyage sec," or "dry cleaning.kerosene
7
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Doing laundry has been a common household activity for years.
Whether the technology was beating the garments on rocks by the
river or pushing buttons on programmed washing machines, this
process depends on water and a mechanical action usually assisted
by soap or an alkali. The purpose of an alkali is to saponify the
oils and dislodge ordinary soil and other matter. More often than
not, the soapy agent holds soil in suspension as it becomes loose
during the wash cycle, and is subsequently flushed away during the
rinse cycle and centrifugal spin. washing machines The drying
process for doing laundry at home is either hanging clothes on a
clothesline or tumbling them in a gas- or electric-heated
dryer.dryer 8
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Dry cleaning, on the other hand, is different. It's a process
that cleans clothes without water. The cleaning fluid that is used
is a liquid, and all garments are immersed and cleaned in a liquid
solvent -- the fact that there is no water is why the process is
called "dry. 9
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Early dry cleaners used a variety of solvents including
gasoline and kerosene to clean clothes and fabrics. In the United
States, the dry-cleaning industry is fairly new and has developed
only during the past 75 years. Since World War II ended, the
volatile synthetic solvents carbon tetrachloride and
trichlorethylene gave way to a product known as perchlorethylene
(perc), which became the overwhelming solvent choice for the
industry. It was not only safer and faster, but did a much better
job of cleaning, required less massive equipment, less floor space,
and could be installed in retail locations offering excellent
quality one-hour service. gasoline and kerosene 10
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As a result of this innovation, the majority of clothes today
are cleaned by perc. A proliferation of cleaning franchises and
dry- cleaning businesses offering fast service from convenient,
clean, and attractive locations evolved to change the industry into
what we see today. 11
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Perc is classified as a hazardous air contaminant by the United
States Environmental Protection Agency and must be handled as a
hazardous waste. To prevent it from getting into drinking water,
dry cleaners that use perc must take special precautions against
site contamination. Landlords are becoming increasingly reluctant
to allow dry cleaners to operate in their buildings. When released
into the air, perc can contribute to smog when it reacts with other
volatile organic carbon substancesUnited States Environmental
Protection Agencyhazardous waste smog 12
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Perc is readily absorbed into the bloodstream both through
inhalation and after oral exposure. Dermal uptake appears to be
complete but slower than other routes of exposure. From the
bloodstream, perc distributes readily into fatty tissues and some
accumulate there. Perc also crosses the placental barrier. Perc is
mostly exhaled unchanged. Regardless of the route of exposure, 1-3%
of the absorbed PERC is metabolized. 13
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The primary route of exposure to PERC is inhalation. 14
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Once taken into the body, some perc can be excreted through
exhalation or (after metabolization) through urine. Metabolized
into TCA trichloroacetictrichloroaceticacid 15
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16 What is the purpose of the Perchloroethylene Dry Cleaner Air
General Permit Notification Form?
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17 The use of an Air General Permit notification form serves a
several purposes: Provides notice to the Department that the
facility is in operation and Prescribes the requirements under
which the facility is allowed to operate [Rule 62-296.310(5)(b),
F.A.C.]
19 A perchloroethylene dry cleaning facility may use a air
general permit provided the: facility meets the eligibility
criteria set forth in the rule and, throughout the term of the
general permit maintains its eligibility to use the general permit
and complies with all terms and conditions of the general permit.
The responsible official of the perchloroethylene dry cleaning
facility shall determine the facilitys eligibility for the Air
General Permit and notify the Department of intent to use the Air
General Permit. Rule 62-213.300(1)(a), F.A.C. Perchloroethylene
(PERC) Dry CleaningPerchloroethylene (PERC) Dry Cleaning - Rule
Requirements
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20 A perchloroethylene dry cleaning facility is eligible to
operate under the terms and conditions of the Air General Permit
established at Rule 62-213.300(1)(a), F.A.C., provided the
responsible official has submitted a completed Part III of this
notification form to the Department at least 30 days prior to
beginning operations under the general permit and throughout the
term of the general permit, all of the following conditions are
met:
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21 The facility operates no emissions units other than
perchloroethylene dry cleaning systems and emissions units which
are considered insignificant pursuant to the criteria of Rule
62-213.300(2)(a)1., F.A.C., set forth in paragraph (1)(b); The
facility is classified as a small or large area source pursuant to
40 CFR Part 63, and
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22 The facility complies with all general conditions of Rule
62-213.300(3)
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23 Notification: For each facility intending to operate under
the provisions of this Air General Permit, the responsible official
must complete and submit Part III of this Perchloroethylene Dry
Cleaner Air General Permit Notification Form [DEP Form No.
62-213.900(2), F.A.C.] to give notice to the Department of intent
to use such permit.
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24 Administrative Corrections: a)Any change in name of the
responsible official or facility address or phone number; b)A
change in facility status requiring more frequent monitoring or
reporting by the responsible official from that noted on the most
recent notification form; and c)Any other similar minor
administrative change at the facility.
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Violation of Permit. This Air General Permit is valid only for
the specific activity indicated. Any deviation from the specified
activity and the conditions for undertaking that activity is a
violation of the permit Violation of the permit constitutes grounds
for revocation Initiation of enforcement action No revocation shall
become effective except after notice is served by personal service,
certified mail, or newspaper notice 25
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Nullification of Eligibility. Eligibility for use of a t his
Air General Permit is automatically nullified by: Submission of
false or inaccurate information in the notification form for use of
the Air General Permit or in the required reports; Refusal of
lawful inspection by Department staff; Failure to submit
operational reports or other information required by the Air
General Permit ; or Failure to timely pay the required fee,
penalty, or interest. 26
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27 General Conditions [Rule 62-210.310(3), F.A.C.] The duration
of this general permit is five years. No later than 30 days prior
to the fifth anniversary of the filing of intent to use this
general permit, the responsible official shall submit a new notice
of intent which shall contain all current information regarding the
facility. The general permit is not transferable and does not
follow a change in ownership of the facility. Prior to any sale,
other change of ownership, or permanent shutdown of the facility,
the responsible official shall notify the Department.
Perchloroethylene (PERC) Dry Cleaning Part II Perchloroethylene
(PERC) Dry Cleaning Part II - Rule Requirements
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28 The responsible official shall make every reasonable effort
to conduct the specific activity authorized by this general permit
in a manner that will minimize any adverse effects on adjacent
property or on public use of the adjacent property, where
applicable, and on the environment, including fish, wildlife,
natural resources, water quality, or air quality.
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30 The responsible official shall allow a duly authorized
representative of the Department access to the permitted facility
or activity at reasonable times to inspect and test, upon
presentation of credentials or other documents as may be required
by law, to determine compliance with this Air General Permit and
Department rules.
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31 Monitoring and Related Recordkeeping and Reporting
Requirements. The responsible official shall maintain records of
monitoring information that specify the date, place, time, and
operating conditions of measurement; the methodology used; the
company or entity which performed the monitoring; and the
analytical results. These shall include all calibration and
maintenance records, original strip-chart recordings for continuous
monitoring instrumentation, and copies of all reports required by
this permit.
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32 The responsible official shall retain records of all
monitoring data and supporting information for a period of at least
five years from the date of collection.
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33 63.320 Applicability (a) applies to operatoring dry cleaning
facility using perc (b) The compliance date for a new dry cleaning
system depends on the date that construction or reconstruction
commences.
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34 63.322 Standards The owner or operator shall close the door
of each dry cleaning machine immediately after transferring
articles to or from the machine, and shall keep the door closed at
all other times. The owner or operator of each dry cleaning system
shall operate and maintain the system according to the
manufacturers' specifications and recommendations.
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35 63.322 Standards Continued The owner or operator of a dry
cleaning system shall inspect the system weekly for perceptible
leaks while the dry cleaning system is operating. Inspection with a
halogenated hydrocarbon detector or PCE gas analyzer also fulfills
the requirement for inspection for perceptible leaks. The following
instrument is used to inspect the drycleaning system:
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63.322 Standards Continued (1) Hose and pipe connections,
fittings, couplings, and valves; 37 (2) Door gaskets and seatings;
(3) Filter gaskets and seatings; (4) Pumps; (5) Solvent tanks and
containers;
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63.322 Standards Continued (6) Water separators (7) Muck
cookers (8) All Filter housings (9) Exhaust dampers (10) Diverter
valves (11) Stills 38
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40 INSPECTIONS : If you buy 140 gallons or more of PERC per
year, you must check your machine weekly for leaks and record the
results. If you buy less than 140 gallons of PERC per year, you
must conduct and record leak inspections at least every other week.
Record the results of the inspections on the calendar. If leaks are
found, they must be repaired within 24 hours. Indicate in the DATE
REPAIRED block when repairs are completed. If parts must be
purchased, indicate the dates they are ordered and the date
installed. Parts must be ordered within 2 working days of leak
detection and installed within 5 working days of receipt.
46 If the facility installs new process or air pollution
control equipment, alters existing process or control equipment
without replacement, or replaces existing process or control
equipment with equipment substantially different than that noted on
the most recent registration form, the owner or operator shall
submit a new and complete AG permit registration form with the
appropriate AG permit processing fee of $100.00 to the Tallahassee
addresses listed later in the presentation.
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47 Submitting your Registration Form for OVERNIGHT DELIVERY:
(FedEx, UPS, DHL, etc.) FDEP 3800 COMMONWEALTH BLVD, MS-77
TALLAHASSEE, FLORIDA 32399
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48 for regular USPS MAIL DELIVERY: (U.S. Mail) FDEP RECEIPTS
POST OFFICE BOX 3070 TALLAHASSEE, FLORIDA 32315-3070
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49 Marnie Brynes Division of Air Resource Management Air
General Permits Program (850) 922-8978
[email protected] or Stephen McKeough Small Business
Environmental Assistance Program Ombudsman 1-800-722-7457 or (850)
921-9539 [email protected]
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50 http://www.dep.state.fl.us/southwest/contacts/
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The Title V yearly statement of compliance forms are not going
to be required when the TV GPs are moved into Non TV GPs. If the
NESHAP requires some frequency of compliance reporting, that will
still be required. 52
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There are no more annual fees for these facilities. The last
annual fee was billed in December 2006 with a payable date in March
2007. Once the rule is finalized the $100 registration fee will
apply. 54
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we are anticipating the rule revisions to be final sometime in
the 1 st quarter of 2011. 55