First Name | Bill |
---|---|
Last Name | Magavern |
Email Address | magavern@sierraclub-sac.org |
Affiliation | Sierra Club California |
Subject | Dry Cleaning ATCM |
Comment | January 24, 2007 California Air Resources Board 1101 I Street Sacramento, CA 95814 Re: Dry Cleaning ATCM Dear Board Members: Sierra Club California thanks the Air Resources Board for ordering a phaseout of Perchloroethylene (PCE) from dry cleaning. Studies of currently available alternative systems indicate that alternative solvents in commercial use today successfully clean as full a range of garments as PCE. Non-PCE alternatives are just as cost-effective or more cost-effective than PCE systems. Moreover, there is no question that the alternative solvent systems are commercially feasible and in broad use within the United States and in other countries. Therefore, California should make the transition away from PCE as soon as possible and assure that replacement systems are safe. We believe the phaseout period for PCE machines should be reduced to 10 years to protect workers and the public. Alternative solvent systems such as wet-cleaning evolved from emerging technologies to commercially viable systems that have taken their place as established technologies in the industry. Numerous studies and reports regarding alternative solvent systems demonstrate that such systems are comparable to PCE systems in quality of cleaning, range of garments cleaned, and cost. As a result, it is now achievable for dry cleaners to eliminate PCE emissions through process changes and substitution of materials. Specifically, when dry cleaners’ PCE machines wear out, they can replace those machines with machines that use non-PCE alternatives. Moreover, they can do so cost-effectively and at no greater cost than using PCE machines. A quicker phaseout of PCE is justified by research findings that point to a 10-year life expectancy for PCE machines. In 2000, William Fisher, Chief Executive Officer at International Fabricare Institute, testified to the US House of Representatives Subcommittee that the anticipated life of a PCE machine is “eight to 12 to 14 years” depending on the model. During its 2001 rulemaking on the phase-out of PCE, the South Coast Air Quality Management District initially proposed a phase out of Perc dry cleaning systems that allowed machines a lifetime of nine to 10 years. In 2005, the Eastern Research Group (ERG), which provided background information for USEPA’s development of the current National Emissions Standards for Hazardous Air Pollutants (NESHAP), quantified the "Economic Life" for a dry cleaning machine as 10 years. In a Memorandum dated May 16, 2005 to US EPA’s Rhea Jones, ERG’s Eric Goehl and Mike Heaney note that the "life of a dry cleaning machine was determined during the development of the current NESHAP.” Additionally, we believe that a full implementation of AB 998 (Lowenthal, 2003) will decrease the actual cost of the transition to safer substitutes. AB 998, which we supported, directed ARB to apply a fee on the PCE used in dry cleaning to establish a demonstration program for non-toxic, non-smog forming alternatives, and use the additional funds for grants to cleaners making the transition from PCE to these safer alternatives. Our understanding is that more than three years after this law took effect ARB: 1) is still not fully collecting fees on all the PCE used by California dry cleaners, 2) has not initiated a single demonstration program, and 3) has only made 23 grants in a state with almost 5,000 dry cleaners. ARB can do more to support cleaners’ transition by fully implementing AB 998. Despite the extraordinary toxicity of PCE, many Americans are unaware of the health risks created by exposure to PCE emissions. This risk is especially high for people who live in the same building as a PCE dry cleaner. The risks are also especially high for people who spend any time in the same building as a PCE dry cleaner — e.g. children who go to a day care center in the same building as a PCE dry cleaner — and for the neighbors of a PCE dry cleaner. Therefore, we support the draft proposal’s requirement for removal of all PCE machines from co-residential locations, and we ask the Board to expedite the removal of PCE machines that are located in close proximity to homes, schools, day care centers and other sensitive sites. Sincerely, Bill Magavern Senior Representative |
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Date and Time Comment Was Submitted | 2007-01-24 09:30:23 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.