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01/27/1998 15:12 GARY MCLEAN INC PAGE 08 5124841903 12251 Tech Road, snver Spring, Maryland 20904 (301) 62:Z~1900 The Drycleaning Industry and the Clean Air Act Amendments Of 199o-Guide to Likely Federal and State EPA Regulations What Are the Clean Air Act Amendments All About? The origioal Oean All Act first became law in 1963, and was last amended In 1977-13 years ago, The new amendments--over 300 pages worth-significantly overhaul and expand existing Clean Air Act requirements. Passed by Congress in late October, the amendments were signed into law by tne President on November 15, 1990. The flnaJ law-which incorporates changes sought by the dryc1eaning industry-is tough but fair. Keel' in mind that the new Oean Air amendments generally set broad-based requirements, not industry- specific equipment standards. Instead, U.S. EPA must develop individual r~lat:ions. for every affected industry. Tnis takes time-and puts the DnaJ decisions on controls 1n EPA's hands. IFt has already been working with EPA'5 Air Office, and have so far found them to be responsive to uS as a small-business industry. As a Plant Owner. What Types of New Regulations Can I Expect? There are eleven key areas (called "Titles") in the Clean Air Act amendments of 1990, of which several will have applicability to the drycleaning industry. These include Title f Non.Attainment (petroleum); Title III Air Toxies (pere); Title V Operating Permits (all solvents); and, Title VI Stratospheric Ozone (F-113 and 1.1 ,1~Tri. chloroethane)---althoug" the "'levelfl of effect wll1 vary. In the following sections, the likely effects and/or direction of regulations are grouped by solvent or type of regulation. PETROLEUM SOL VENT PLANTS How Do Petroleum Emissions Fit In Under the Clean Air Act? Petroleum solvent is a hydrocarbon mixtu~. Hydrocarbons break down in the lower atmosphere to form ozone, the primary constituent In smog. O.:;one is known as a "conventional pollutant;" the maximum allowable level Is 0.12 ppm. Areas in a state that exceed this level are required to controt emisSions of hydrocarbons and other pn,,;ursor9 that rontribute to ozone and smog formation. Whet Type of New Regulations Can I Expect? No new emission standards will be required, as EPA has previously issued a eTG "model" regulation for existing plants and Q NSPS regulation for new or modified plants. Some states ?f cities ,may have to tighten up on exemption levels for exJsting pfants--see the next questions for further Information on this. What Are the Existing Regulations for Petroleum Plants? In brief the erG "sample" regulation sent to the states In 1982 recommended a 32,500 gallon per year exemptio~ level for existing plants. If a plant used mOre than that, states ~ere el\courage~ to adopt. a regulation that would require existing plants to instalJ petroleum recovery dryers In place of tlieu conventlonaf dryers, and-if filtration was being used-to use only cartridge filters (or some other system that gave no more than 0.15 gallons lost per every 100 pounds cleaned). . . The federal NSPS standard-in effect since December 14, 1982-requires that any new or eXisting petroleum plant can only purchase a recovery dryer- if purchase of a new or replacement dryer would give more than 84 pounds of total petroleum dryer capacity in the plant. Additionally, an~ new or replacement filter system that is purchased must be a cartridge filter (or have very low solvent loss In wastes). ...... 7 ~ 0: ~ ~ tr1 ,::j Z ~ ~ z r > ~ :x z o . VJ