State of California
AIR RESOURCES BOARD
The Ambassador Hotel
3400 Wilshire Blvd.
Los Angeles, CA
October 22, 1980
80-20-1 CONTINUATION OF Public Meeting to Consider 001
Suggested Control Measure for the Control of
Volatile organic Emissions from Perchloroethylene
80-20-2 Public Hearing to Consider Repeal of 1955-1965 051
Model Year Motor Vehicle Exhaust Retrofit Emission
Control Requirements - Title 13, California
Administrative Code Section 2007.
80-20-3 Public Hearing to Review Adoption by the South 074
Coast Air Quality Management district of Rule
1005.1, Control of Vinyl Chloride Emissions.
80-20-4 Other Business
a. Executive Session
b. Delegations to Executive Officer
ITEM NO.: 80-20-1
Public Meeting to consider Suggested Control Measure for the
Control of Volatile Organic Emissions from Perchloroethylene Dry
SUMMARY AND STATEMENT OF REASONS FOR SUGGESTED CONTROL MEASURE
The California Air Resources Board (ARB) is considering approval
of a suggested measure for the control of volatile organic
compound (VOC) emissions from perchloroethylene dry cleaning
operations. If approved by the Board, the suggested control
measure will be forwarded to appropriate air pollution control
districts (APCDs) for consideration as amendments to their rules
and regulations to the extent necessary to provide for attainment
and maintenance of state and national ambient air quality
standards for oxidant and ozone, respectively. The proposed
control measure will establish a guideline as well as a technical
basis for local district consideration; however, it will become
an enforceable regulation only after it si adopted into the rules
and regulations of a district. Approval by the Board of the
proposed control measure does not create an enforceable
regulation which would be legally binding on the
perchloroethylene dry cleaning industry.
Currently, the state and national ambient air quality standards
for oxidant and ozone are violated in most urban areas of the
state. Perchloroethylene dry cleaning operations within these
areas emit perchloroethylene in significant amounts during the
cleaning and drying of clothing, disposing of solvent filters,
and other processes of the dry cleaning operations. The
emissions of perchloroethylene into the atmosphere from these dry
cleaning facilities contribute to the occurrence of complex
photochemical reactions which result in the formation of a
variety of atmospheric photochemical oxidants, including ozone.
The Federal Clean Air Act requires that states attain and
maintain the national ambient air quality standards for ozone.
The California Health and Safety Code requires that local APCDs
endeavor to achieve and maintain state ambient air quality
standards, including the standard for oxidants.
The staff of the Bay Area Air Quality Management District
(BAAQMD) in cooperation with the ARB, Environmental Protection
Agency (EPA) and other APCDs, has developed a suggested measure
for the control of emissions from perchloroethylene dry cleaning
operations. The background information used to develop this
suggested control measure includes the following: information
from BAAQMD, including the BAAQMD staff report; information from
EPA, including the Control Techniques Guideline (CTG) for Control
of Volatile Organic Emissions from Perchloroethylene Systems;
information collected by the ARB staff during visits to dry
cleaning operations; information published in the Federal
Register; ARB emission inventory data (which reflect data
obtained from the APCDs); and other information cited or reported
in the ARB staff report.
The ARB staff report and the above referenced documents are
available for public inspection at, and the staff report may be
obtained from, the Air Resources Board Public Information Office,
1102 Q Street, Sacramento, CA 95814 on or after August 8, 1980.
Emission control technology currently available for the control
of emissions from perchloroethylene dry cleaning operations
includes carbon adsorbers and vapor condensers. Carbon
adsorption controls, which are acceptable to the EPA, ARB, BAAQMD
and other APCDs, have been found to be reasonably available to
control this source of emissions. Vapor condensation control
equipment is also available for efficient control of
perchloroethylene emissions. Both of these controls allow for
capture and reuse of the perchloroethylene solvent. Considering
the present cost of perchloroethylene, approximately $3.50 per
gallon, the cost-effectiveness for control is estimated to range
between $0.19 (savings)/lb reduced for larger industrial dry
cleaners to $0.50 (cost)/lb for the smallest facilities which are
subject to controls for this measure (320 gallons per year
facility). These costs are based on EPA and BAAQMD economic
evaluations of sample dry cleaning operations. The ARB staff has
confirmed these cost-effectiveness estimates and concurs with
The statewide estimate of emissions from perchloroethylene dry
cleaning operations is 48 tons per day (based on ARB's 1979
emission estimates). An overall emission reduction of about 50
percent is expected from the existing, uncontrolled
perchloroethylene dry cleaners upon implementation of this
suggested control measure by the districts. Most of the sources
in this category are located in the Bay Area and the South Coast
Air Quality Management Districts.
The proposed measure would require that all drying tumblers and
cabinets be vented to a carbon adsorber or other control device
operating at a 90 percent minimum efficiency (by weight) or
controlled to a level of 100 ppm (by volume) during the entire
drying cycle (before dilution). This provision of the suggested
control measure will apply to dry cleaning operations consuming
more than 320 gallons of perchloroethylene per year. Dry
cleaning establishments which consume less than 320 gallons of
perchloroethylene per year would be exempt from these
requirements due to the relatively poorer cost-effectiveness
anticipated for reducing emissions from these smaller operations.
Coin operated cleaners (coin-ops) also would be exempt from the
provision requiring installation of emission control devices.
The proposed measure would further require that all dry cleaning
operators immediately repair all perchloroethylene solvent leaks
from their equipment. In addition, all perchloroethylene-laden
waste would have to be stored in sealed containers. Final
disposal of such waste is already governed by State law.
Used filtration cartridges would have to be stored for 24 hours
in the filter cartridge housing or vented to the control device
for a 12 hour period. Diatomaceous earth filters would have to
be cooked or treated so that no more than 0.25 kg. of solvent per
kg. of wet waste remains. The measure would also require that
perchloroethylene solvent distillation residue contain not more
than 0.6 kg. of solvent per kg. of wet waste.
The principal environmental effect of this measure would be a
definite benefit to ambient air quality due to a reduction of
atmospheric perchloroethylene emissions. No significant adverse
environmental impacts of this measure have been identified.
ITEM NO.: 80-20-2
Public Hearing to Consider Repeal of 1955-1965 Model Year Motor
Vehicle Exhaust Retrofit Emission Control Requirements - Title
13, California Administrative Code Section 2007.
SUMMARY AND STATEMENT OF REASONS FOR PROPOSED RULEMAKING
Commencing in 1972 the state Legislature required that (pursuant
to Health and Safety Code Section 43652) every 1955 through 1965
light-duty motor vehicle subject to registration in this state be
equipped with a certified device to control its exhaust
emissions. Installation of retrofit devices was required either
upon transfer of ownership and registration, or upon initial
registration of a vehicle not previously registered in this
state. The implementation of this retrofit program was in
accordance with a schedule adopted by the Air Resources Board.
The implementation schedule commenced on September 1, 1972, in
the South Coast Air Basin, December 1, 1972, in San Diego Air
Basin, and March 1, 1973, in the San Francisco Bay Area Air
Basin. The 1955-65 retrofit program is currently ongoing in
these three air basins.
Senate Bill 13, which was passed in 1976, requires that the Board
annually review the 1955-65 exhaust retrofit program. In making
this review, the Board is required to consider all relevant
factors including, but not limited to, the fact that the
requirement is being imposed on a constantly decreasing number of
motor vehicles. If the review supports termination of the
program, the Board may make a determination by regulation that
such a requirement is no longer needed to achieve or maintain
ambient air quality standards in any air basin. In adopting such
regulations, however, the Board must assure that all 1955-65
model year light-duty motor vehicles equipped with an exhaust
retrofit device prior to termination of the program continue to
be so equipped.
The staff report contains a detailed discussion of the need for
the repeal and the substantive facts, including references to
relevant studies, on which the proposal is based.
The analysis in the staff report regarding this matter looks
primarily at the costs and emission benefits of retaining the
program, while highlighting various other factors which should be
used to determine the relative merits of continuing or
terminating the program.
Based upon the analysis, the staff recommends that the 1955-65
exhaust retrofit program be terminated. The principal
conclusions supporting this recommendation are:
1. The estimated additional emission reductions (termination in
1980 vs. continuing through 1985) are minuscule. These
reductions would amount to approximately one ton per day (HC
plus NOx) for all three major air basins combined.
2. Assuming the fuel economy penalties associated with the
retrofit programs remain constant, additional expected fuel
cost increases through 1985 will undermine the incremental
3. The cost effectiveness of performing maintenance (including
retrofit device) on 1955-65 model year vehicles is worse
than for later model vehicles and the cost of inspection and
repairs outweigh the annual emissions benefits.
4. Due to increasing operating costs of the service industry,
it is becoming unprofitable for businesses to sell and
install retrofit devices which are price-controlled by law
to 1973 prices.
5. With the declining number of vehicles in these two
population groups and their declining usage beyond 1980, the
emissions reduction potential of the exhaust retrofit
program decreases markedly.
ITEM NO.: 80-20-3
Response to "Petition Pursuant to California Health and Safety
Code Section 40451 to Review Adoption of Rule 1005.1, Control of
Vinyl Chloride Emissions, by the South Coast Air Quality
The staffs of the Stationary Source Control Division and of the
legal Affairs and Enforcement Division of the California Air
Resources Board have reviewed the petition submitted by the B.F.
Goodrich Company entitled:
Petition Pursuant to California Health and Safety Code
Section 40451 to Review Adoption of Rule 1005.1, Control of
Vinyl Chloride Emissions, by the South Coast Air Quality
The staff does not dispute the petitioner's assertion that
polyvinyl chloride does, indeed, represent a product which is
important to the economy of the State of California, and which
has no adequate substitutes. However, the staff has not been
able to substantiate B.F. Goodrich's claims that the South Coast
Air Quality Management District (SCAQMD) rule 1005.1 is
"ambiguous", "arbitrary", "unreasonable", or "unclear", nor has the
staff found any claimed inconsistencies between the rule and
Division 26 of the California Health and Safety Code.
Additionally, the staff does not agree with the petitioner's
contention that the National Emission Standard for Hazardous Air
Pollutants (NESHAP) for vinyl chloride, or the SCAQMD Rule 1005
which is patterned after the NESHAP, is adequate for the
protection of public health, nor does the staff agree with the
petitioner that the NESHAP, or rule 1005, in all cases represents
best available control technology (BACT). Further, the staff
does not believe this issue is relevant to the subject of B.F.
Goodrich's petition, which is the validity of South Coast
District Rule 1005.1, and that Rule's consistency with the
purposes of Division 26 of the Health and Safety Code.
The staff recommends that the Board find Rule 1005.1 to be
consistent with Division 26 and recommends that the Board deny
the relief requested in the petition by taking no action to
repeal or cause to be repealed Rule 1005.1.