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<br />01/27/1998 15:12
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<br />5124841903
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<br />GARY MCLEAN INC
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<br />PAGE 10
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<br />OPERA TING PERMITS-ALL PLANTS
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<br />What Are the New Clean Air Requirement?
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<br />All sources of emissions-Including all drycleaning plants-will have to comply with future permitting requirements.
<br />EPA wUl provide guidance to the states, and In three years each state must submit Fermit programs to EPA for approval.
<br />State programs must Indude certain minimum requirements, including an aonua fee of least $25 per ton of emissions.
<br />This fee will Increase each year by the Consumer Price Index.
<br />States are authorized to setup a "general permit" system for indust!es where there are "numerous similar sources" which
<br />would apply. to our industry. Individual applications would still have to be made, but the permitting process "';ould be
<br />greatly simphfied. (PI has already begun discussion with EPA's Air Office on this.
<br />AddItionally, each state must-within lwo yea.rs--set up a "small business stationary source technical and environ~
<br />mental compli8l\ce assistance program" to minimize the burden on sma1J businesses. Further, states may then reduce
<br />permit fees below the $25 per ton figure for small businesses.
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<br />How Much Money Are We Talking About?
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<br />Por per: plants, emissions will vary with solvent mileage-and need to be calculated after subtracting out the perc
<br />sent out In hazardous waste shipments. Under average conditions, a plant with 9,000 Ibe/drum solvent mileage emits
<br />only about 59 2~r~ent of the total perc i~ uses, With the rest goIng out for hazardous waste treatment., Therefore, every
<br />five drums (3,500 Ibs of pete) would gIVe on.e ton of emissions, As a ball park figure, then, appro;nmately every five
<br />drLmts of solvent used would cost about $2.5 in emission fees.
<br />For P-113 and 1,1,Hrichloroethane, the figures are too variable to give an "average" for permit fees. However, an
<br />individual plan.t can calcuJate this for their own operation by taking their solvent purchases for a year and subtracting
<br />out the approximate amount of solvent 5ent out for hazardous waste disposal. Once you have the amount of emission,
<br />tht11 every 180 gallons of 1,1,1 equals ont ton of emissions, and ~ery 152 gallons of F-l13 equals one ton of emissions.
<br />Por petroleum plants, the situation is somewhat different. If hazardous waste disposal Is not used, dryer losses and
<br />wastes sent to a landfill contribute to air emissions. In this case, each ton of emissIOns is equal to approximately 310
<br />gallons of solvent used.
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<br />BRIEF GLOSSARY OF TERMS
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<br />Air Toxics: A list of 189 chemicals has been specifically designated by Congress as "air toxies," primarily on the basis of
<br />a suspicion of possible carcinogenicity. Perchloroethylene and l,I,l-trichloroethane are included on the list of air toxics.
<br />AUa1nment: An area in a state that meets applicable federal standards for "conventional" pollutants, such as ozone, oxides
<br />of nitrogen, etc. An area can simultaneously be attainment for one of these pollutants, but non-attainment for others.
<br />crG: Control Technique GuideUne. A model or "sample" standard sent by U.s. EPA to state EPA's. The CTG documents
<br />do not have to be adopted by the states, but there are factors related to federal funding of projects that encourages them
<br />to do so. StateS can adopt a more stringent standard than that suggested in the CTC. CTC's have been issued for both
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<br />existing pere and ~troleum plants.
<br />Conventional Pollutant: "Normal" pollutants, 5uch as ozone, sulfur dioxide, and nitrogen oxides. These are the
<br />pollutants that result from our general industrialized society, and come from hydrocarbon emissions, boiler emissions,
<br />automobile and ttuck exhaust, etc.
<br />Fa-dUty: For our Industry, EPA has usually defined a "facility" as the individual operating component of a machine.
<br />for example. a perc cleaning machine and/or tumbler is defined as a facility; a petroleum dryer is a facility; a petroleum
<br />filter system is a facility.
<br />CACT: Generally Available Control Technology-a level of control \hat is generally in use and is economically affordable,
<br />MAeI': Maximum Avallable Control Technology" -with some minor variations, essentially defined. as a level of
<br />control that is equal to that being achieved by the best single operating plant in an industry,
<br />NSPS: New Source Performance Standard-federal EPA standard that applies to any new or modified "facility."
<br />Precursors: MY compound that-by breaking down-leads to formation of a pollutant. Hydrocarbon emissiol'1s are
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<br />an O;l:one precursor.
<br />RACT: Reasonably Available Control TechnologY---E'ssential1y the same as "CACf," which is a term Congress has just
<br />created. At the point. no one is certain of the dffference-if any-between RACf and CACT.
<br />Residual IUBk: The possible risk of cancer to the nearest individual living-or possibly working-near to a fad Ii ty.
<br />EPA wil1 be required to report to Congress by 1996 on .the "residual risk" possibly remaining after industries with air
<br />toxies have put in new equipment or controls that quahfy as MAcr. , .
<br />VOC: Volatile Organic Compound-a chemical that reacts in the atmosphere to form ozone. Hydrocarbon emiSSions
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<br />are the primary precursors for ozone formation.
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<br />ThiS bulletin written by William E. fisher, IFI's Assistant General Manager jVice Pre!ident
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