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<br />01/27/1998 15:12
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<br />5124841903
<br />
<br />GARY MCLEAN INC
<br />
<br />PAGE 09
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<br />'What Are Some of the Major General Requirements Under Air Toxics?
<br />
<br />The first is that allernission sources wUl be grouped as either a major source (10 tons ot emissions or more per year),
<br />or an artt2 source (less than 10 ton8 emissions per year). Keep in mind that these are air emissions, not total soivent
<br />consumption. When hazardous waste disposal 19 used, the perc content in that waste is no longer an air emission.
<br />Taking that into account, a plant with a solvent mlieage of 6JXX} Ibs/drum can dean about 4,500 Ibs/week before exceeding
<br />10 tons of emIssions per year. If solvent mileage is about 9,000 lbs/drum, than about 8,400 Ibs can be cleaned per week if
<br />mileage is about 12,000 IDs/drum, than about 14,800 Ibs per week can be done. Finally, 18,000 lbs/drum would typically
<br />allow "55,000 Ibs of cleaning per week before 10 tons of emissions are exceeded. Obviously, every plant in the country Can-<>r
<br />should be able to-meet the definition of an area sourCE.
<br />The drawback to being classified as a major source? "Maximum Available Control Tt!Chnoiogy" will be required, where
<br />any new or existing source must achieve emission controls equal to that already being achieved by the best single plant
<br />in the industry. Further, future standards on "residual risk" ("possible" carcinogenicity) to the nearest exposed
<br />individual living or working around the plant maybe required-and equipment put In to meet a MACT standard might
<br />not meet a "residual risk" standard.
<br />
<br />What Can We Most Likely Expect In Terms of Regulations?
<br />
<br />EPA has already been working on perc standards for two years. Right now, we expect those to be proposed by late 1991,
<br />with final regulations expected in mid-to late 1992. IFI has already been meeting with EPA's Air Office. While there art! no
<br />guarantees, their current direction on proposed standards for perc drycleaning is as follows:
<br />.: New Plants: A requirement for dry-to-dry" no ven.t" refngerated cleaning machines.
<br />. Existing Plants: For current dry-to-dry "no vent" machInes, no Further equipment requirements. Por transfer and
<br />venled dry-to-dry operations, a requirement (or carbon vapor ad50rbers-with the possibHity that add-un retiigerated
<br />condensers may be allowed as an alternative to carbon adsorbers.
<br />.' Modified Plants: The Clean Air Act normally requires that an existing plant that ref laces old equipment must then meet
<br />the requirements for a new plant. However, EPA may allow the very smallest 0 plants-who will already have been
<br />required to install an adsorber or add-on refrigerated condenser-to replace their drycleamng machine or tumbll!:r instead
<br />of requiring them to purchase a new dry-to-d.ry refrigerated machine.
<br />The industry was successful in getting specific language in the law titating that EPA should look at Uwork practice
<br />standards" for industries such as ourselves. This is exactly the direction in which IFI has been encouraging EPA's Air
<br />Office, where proper equipment and operations should be specified in a regulation, instead of numerical standards
<br />and/or emission monitoring requirements! AdditionaUy, Congress has stated that emissions monitoring need not be
<br />required if it is not practical because of technology or economics.
<br />
<br />What Other Information Should I Know About?
<br />
<br />Within one year, EPA must publish a list of all major and area source categories by industry. In five years, EPA must
<br />publish a list of enough area sources to assure that 90 pe:rcent of the emissions of the 30 "most serious" area source
<br />pollutants are regulated. Within an additional five years, EPA must regulate these sourc~s. Bec~use of this, we ma~ be
<br />fortunate in having the perc standard completed early on, rather than later when EPA 1S lookmg for ways to ach1eve
<br />the total 90 percent reduction.
<br />
<br />1,1,1-TRICHLOROTHANE AND F-113 PLANTS
<br />
<br />What Are the Key Provisions Under the Clean Air Amendments?
<br />Because of ozone depletion in the stratosphere, futu.re production of l,l,l-trichloroethane wilt be reduced. The
<br />reduction schedule for "regular" fluorocarbons (such as 1=-113) has been reeet, and fluorocarbon substitutes (HCPC's)
<br />will also ultimately be phaSed out.
<br />
<br />What Can I Expect To Happen?
<br />
<br />First, a continued escalation of F-113 prices, whi~h ~re already typically in .a $70 per gall.on range. Phase-out will continue
<br />over the next ten years, while production taxes w1ll Increase; as a result, pnces w1ll continue to escalate:
<br />For 1.1,1-trlchloroethane, prOduction reductions wiIJ start in 1~3 and continue t? 2002. T~xes win also be pha~d
<br />in: per gallon, these will be $1.52 in 1991-92. $1.85 in 1993, $3.33 10 1~94, and $3.44 10 1995. Given both the productl.on
<br />reductions and taxes, we are likely to see increases in prices starting next year, although not of a level seen with
<br />fluorocarbons. Phase-<Jut schedules-effective each January 1-are as follows:
<br />
<br />, ,Year of R8d1ict1on -
<br />F-tt3 (Reduction frOm t~8818VeI.)
<br />1. 1, 1 [ReduCtiOD from t9891evela)
<br />
<br />1991 190iiII 1093 199.4 1995 199& 1997 1998 1999 2000 2001 2002
<br />. 85% 80~ 75%, 65% 501M1 40~ 15% lS% 15~ 0 0 0
<br />,100% 100% 90% 8S,," 70% 50'*' 50% 50% 50% 20% 20% 0
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