|
NOTE:
Site links are available at the
bottom of all pages.
|
|
John
E. Conover, Jr., P.E.
Wholistic Environmental Consulting, Ltd.
Post Office Box 246
Stony Brook, Long Island, New York
11790-0246
(631)428-6473
E-mail: jconoverjr11790@yahoo.com
Please note that we cannot work in New
York State
Anyplace else in the world is OK!
return to the home page
Environmental Self Audit for Rhode Island Dry
Cleaners
which is designed to determine compliance with the:
RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL
MANAGEMENT
OFFICE OF AIR RESOURCES
AIR POLLUTION CONTROL REGULATION NO.23:
CONTROL OF PERCHLOROETHYLENE EMISSIONS FROM
DRY CLEANING OPERATIONS
The purpose of the following audit is to help the dry cleaners in Rhode Island
determine for themselves if they
are in compliance with the Rhode Island Regulation 23. The owner or operator of a dry
cleaning facility should
read through the audit and answer the questions that are in bold face type. The entire
text of the regulation is also
included and the regulation is not in bold face type
This audit questionnaire has been prepared by John E. Conover, Jr., P.E. ,
Environmental Consultant.
Please contact me if you have any questions about the audit, or you need assistance, or if
you have any comments
or suggestions:
Email: jconoverjr11790@yahoo.com
Website: www.jconoverjr.com
Mailing address: John E. Conover, Jr., P.E.
PO Box 246
Stony Brook, Long Island, New York
11790
Phone: 631-428-6473
Please note that the audit is in bold with roman numerals, and for reference,
Reg. 23 is not bold, and with arabic numerals.
Date of Audit: _________________________________
Name of the store: __________________________________________________
Address: __________________________________________________________
Owner’s Name: _____________________________________________________
Manager’s Name: __________________________________________________
Phone #: __________________________________________________________
Co Located? Stand Alone?
Adjoining structures/stores:
_______________________________________________________________
Date store opened: __________________________________________________
Date the current owner bought the store: _______________________________
Generation of the dry cleaning machine :_______________________________
Regulation 23: Control of Perchloroethylene Emissions from Dry Cleaning Operations
23.1 Definitions
As used in this regulation, the following terms shall, where the context permits, be
construed as follows:
23.1.1 "Articles" means clothing, garments, textiles, fabrics, leather goods,
and similar materials.
23.1.2 "Carbon adsorber" means a dry cleaning control system that consists of
an inlet for exhaust gases; activated carbon in the form of a fixed bed, cartridge or
canister as an adsorbent and an outlet for exhaust gases; and a system to strip or desorb
solvent from the saturated adsorbent.
23.1.3 "Closed-loop Machine" means a dry-to-dry machine that recirculates
perchloroethylene-laden vapor through a refrigerated condenser and that does not exhaust
to the atmosphere during the drying cycle. A closed-loop machine may allow venting to the
ambient air through a local exhaust ventilation system, such as a door fan, after the
drying cycle is complete and the machine door is open.
23.1.4 "Co-located" means sharing a common wall, floor, or ceiling with a
residence or a separately owned business.
23.1.5 "Colorimetric detector tube" means a glass tube which is designed to
measure the concentration of perchloroethylene in air drawn through the tube and that
contains a sorbent material which is impregnated with a chemical that is sensitive to
perchloroethylene.
23.1.6 "Cool-down" means the portion of the drying cycle that begins when the
heating mechanism deactivates. During the cool-down period, the refrigerated condenser
continues to reduce the temperature of the air circulating through the drum to reduce the
concentration of perchloroethylene in the drum.
23.1.7 "Day care center" means any person, firm, corporation, association or
agency who, on a regular or irregular basis, receives any child under the
age of sixteen years, for the purpose of care and/or supervision, apart from his parent
or guardian, for any part of a twenty-four hour day.
23.1.8 "Department" means the Rhode Island Department of Environmental
Management.
23.1.9 "Desorption" means the regeneration or stripping of a carbon adsorber
of the adsorbed solvent using hot air, steam or other means.
23.1.10 "Director" means the Director of the Rhode Island Department of
Environmental Management.
23.1.11 "Distillation unit" means a device used to volatilize and recover
perehloroethylene from contaminated perchloroethylene.
23.1.12 "Diverter valve" means a flow control device that prevents room air
from passing through a refrigerated condenser when the door of a dry cleaning machine is
open.
23.1.13 "Door fan" means a local exhaust ventilation system that pulls room
air into the dry cleaning machine when the machine door is open.
23.1.14 "Drum" means the rotating cylinder or wheel of the dry cleaning
machine that holds the articles being cleaned.
23.1.15 "Dry Cleaning" means a process used to remove soil, grease, paint and
other unwanted substances from articles using perchloroethylene as a solvent.
23.1.16 "Dry Cleaning Control System" means equipment used to reduce the
amount of perchloroethylene in an air stream prior to discharge to the atmosphere.
23.1.17 "Dry Cleaning System" means all equipment, devices or apparatus
associated with dry cleaning operations including, but not limited to: dry-to-dry
machines; transfer machine systems; perchloroethylene filter and purification systems;
perchloroethylene waste holding, treatment and disposal systems; perchloroethylene supply
systems; dip tanks; pumps; gaskets, piping, ducting, fittings, valves or flanges that
convey liquid perchloroethylene or perchloroethylene-contaminated air; and dry cleaning
control systems.
23.1.18 "Dry-to-Dry Machine" means a dry cleaning operation in which washing
and drying are performed in the same machine.
23.1.19 "Dryer" means a machine used to remove perchloroethylene from
articles by tumbling them in a heated air stream.
23.1.20 "Drying Cycle" means the portion of a dry cleaning machine’s
operating cycle in which the perchloroethylene remaining in the articles after washing and
extraction is actively removed. The drying cycle begins when the heating coils are
activated and ends when the machine ceases rotation of the drum.
23.1.21 "Drying Sensor" means a device that senses the perchloroethylene
concentration in the drying air or the liquid solvent recovery rate. The drying sensor
automatically extends the drying cycle for a set time beyond the activation point to
ensure that the articles are dry before being removed from the machine. Drying sensors
include, but are not limited to: infrared analyzers, float switches, and resistance
probes.
23.1.22 "Exhaust damper" means a flow control device that prevents the
air-perchloroethylene gas-vapor stream from exiting the dry cleaning machine and flowing
into a carbon adsorber before room air is drawn into the dry cleaning machine.
23.1.23 ‘Facility" means all pollutant-emitting activities which belong to
the same industrial grouping, are located on one or more contiguous or adjacent
properties, and are under the control of the same person (or persons under common
control). Pollutant-emitting activities shall be considered as part of the same industrial
grouping if they belong to the same major group’ (i.e. which have the same two-digit
code) as described in the Standard Industrial Classification Manual, 1987.
23.1.24 "Filter" means a porous device through which perchloroethylene is
passed to remove contaminants in suspension. Examples of filters include, but are not
limited to, lint filter (button trap), cartridge filter, tubular filter, regenerative
filter, prefilter, polishing filter, and spin disc filter.
23.1.25 "Heating coil" means the device used to heat the air stream
circulated from the dry cleaning machine drum after perchloroethylene has been condensed
from the air stream and before the stream reenters the dry cleaning machine drum.
23.1.26 "Muck Cooker" means a device for heating material trapped by a filter
in a dry cleaning machine for the purpose of driving off perchloroethylene vapors for
reclaiming.
23.1.27 "Perchloroethylene Dry Cleaning Facility" means a facility engaged in
dry cleaning using perchloroethylene. The facility includes, but is not limited to, any
dry cleaning system and attendant stacks.
23.1.28 "Primary Carbon Adsorber" means a carbon adsorber used to control
process vent emissions from a transfer machine system or a dry-to-dry machine that is not
a closed-loop machine.
23.1.29 "Reclaimer" means a machine used to remove perchloroethylene from
articles by tumbling them in a heated air stream.
23.1.30 "Refrigerated Condenser" means a dry cleaning control system that
removes condensable vapors from a gas-vapor stream by cooling the vapors using a
mechanical refrigerated system.
23.1.31 "Secondary Carbon Adsorber" means a carbon adsorber that is designed
to further reduce the perchloroethylene concentration in the gas-vapor stream after the
stream is cooled by a refrigerated condenser.
23.1.32 "Transfer Machine System" means a multiple-machine dry cleaning
operation in which washing and drying are performed in different machines. Examples
include, but are not limited to:
(a) A washer and dryer(s);
(b) A washer and reclaimer(s); or
(c) A dry-to-dry machine and reclaimer(s).
23.1.33 "Water Separator" means a vessel that uses gravity to physically
separate
liquid perchloroethylene from liquid water.
23.2 Applicability
The provisions of this regulation apply to all perchloroethylene dry cleaning
facilities.
23.3 Compliance Certification
23.3.1 Prior to installation of perchloroethylene dry cleaning equipment, the owner of
a dry cleaning facility must certify to the Director, in writing and on a form provided by
the Department, that the proposed installation complies with the requirements of this
regulation. The certification must be signed by the owner of the facility. Any dry
cleaning machine that is installed on or after December 2, 2003 must be in compliance with
the requirements of this regulation upon start-up.
I. Was the dry cleaning machine installed after Dec 2, 2003? Yes No.
II. If yes, did the owner send a certification letter to the department? Yes No _____
____
23.3.2 If the ownership of a perchloroethylene dry cleaning
facility changes, the new owner must notify the Department in writing within 45 days that
the change has occurred. The notification shall include the name and address of the
facility, the name of the new owner or operator, and a certification, signed by the new
owner, that the facility is in compliance with the requirements of this regulation.
Has the ownership of the dry cleaning facility changed after Dec 2, 2003? Yes No
If yes, has the new owner sent a notification and letter of certification to the
Department? Yes No
23.3.3 The owner of any facility that modifies a dry cleaning system or any part of
a dry cleaning system shall certify in writing to the Department before beginning
operation of the modified equipment that the modified dry cleaning system is in compliance
with this regulation.
V. Has the owner of the facility modified the dry cleaning system or any part of the
dry cleaning system after Dec 2, 2003? Yes No
VI. If yes, has a certification letter been sent to the Department? Yes No
23.4 Equipment requirements
23.4.1 Any perchloroethylene dry cleaning machine installed after December 2,
2003 shall be a closed-loop machine with a refrigerated condenser, a secondary carbon
adsorber and a drying sensor. The perchloroethylene laden gas-vapor stream shall pass
through the carbon adsorber immediately before the door of the dry cleaning machine is
opened. A dry cleaning system that uses another type of dry cleaning control system may be
installed only if the Director and the Regional Administrator of the United States
Environmental Protection Agency determine, prior to installation of the system, that the
control system is equivalent to the system specified in this subsection.
VII. Was the dry cleaning machine installed after Dec 2, 2003? Yes No
VIII. If yes, is it fourth generation? Yes No
IX. If no, is the control system approved by the USEPA? Yes No NA
23.4.2 Any perchloroethylene dry cleaning machine installed after 1 August
1988 and before December 2,2003 shall be a closed-loop dry-to-dry machine with a
refrigerated condenser.
X. Was the dry cleaning machine installed between August 1 1988 and Dec 2, 2003? Yes
No
XI If yes, is it a 3rd or 4th generation? Yes No
On and after December 2, 2008, all perchloroethylene dry cleaning machines shall be
closed-loop dry-to-dry machines equipped with a refrigerated condenser and either:
(a) A secondary carbon adsorber and drying sensor, such that the perchloroethylene
vapor-gas stream passes through the carbon adsorber immediately before the door of the dry
cleaning machine is opened; or
A door fan/local exhaust ventilation system.
XII After Dec 2, 2008, 3rd generation machines have to be converted to 4th generation,
or they need to have a door fan added.
23.4.3 Any perchloroethylene dry cleaning machine installed on or before 1 August 1988
shall be a closed-loop machine or shall be equipped with one of the following control
devices by 1 January 1989:
(a) A primary carbon adsorber; or
A refrigerated condenser system.
XIII. Was the machine installed on or before Aug 1, 1998? Yes No
XIV. If yes, is it 3rd or 4th generation? Yes No
XV. If no, did it have control equipment installed by January 1989
(primary carbon adsorber or refrigerated condenser system) Yes No
23.4.4 No person shall operate a transfer dry cleaning system or a dry-to-dry machine
that is a closed-loop machine after December 2, 2005. All transfer machines and dry-to-dry
machines that are not closed-loop machines must be removed from the facility or made
permanently inoperable by that date.
XVI. Does the facility have a 1st or 2nd generation machine? Yes No
XVII. If yes, the machine must be removed from service by December 2, 2005.
23.5 Specifications for Refrigerated Condensers and Drying Sensors
Refrigerated condenser and drying sensors operated to comply with section 23.4 of this
regulation shall adhere to the following specifications:
23.5.1 The outlet temperature of the air-vapor stream downstream of any bypass of the
refrigerated condenser shall not exceed 45 degrees F. during the final cool-down cycle.
XVIII. Does the air-vapor stream downstream of any bypass of the refrigerated
condenser exceed 45 degrees F. during the final cool-down cycle? Yes No
XIX. If yes, repair or maintenance is needed.
The door of the dry cleaning machine shall not be opened until the temperature of the
stream is at or below 45 degrees F, as indicated by a temperature gauge meeting the
specifications of subsection 23.5.2.
XX. Is there a temperature gauge? Yes No
XXI If no, one is needed.
XXII. Is it possible to open the door of the machine before the temperature is at or
below 45 degrees F.? Yes No
XXIII. According to the operating manual, should it be possible to open the door before
the temperature is at or below 45 degrees F. ? Yes No.
23.5.2 A dry cleaning system with a refrigerated condenser must be equipped with a
temperature gauge that measures the temperature of the outlet vapor stream downstream of
any by-pass of the condenser and that is easily visible to the operator. The temperature
gauge must be designed to measure a temperature of 45 degrees F with an accuracy of ±2
degrees F;
XXIV. Is the temperature gauge designed to measure a temperature of 45 degrees F
with an accuracy of ±2 degrees F? Yes No
XXV. If no, the temperature gauge must be replaced with one that is acceptable.
23.5.3 Dry cleaning equipment equipped with a refrigerated condenser shall not vent or
release the gas-vapor stream while the drum is rotating;
XXVI. Does the refrigerated condenser vent or release the gas-vapor stream while the
drum is rotating? Yes No
If yes, repairs or maintenance is needed.
23.5.4 Refrigerated condensers shall be certified by the manufacturer to reduce the
perchloroethylene concentration in the drum to no more than 8600 ppm upon completion of
the drying cycle.
XXVIII. Is the refrigerated condenser certified by the manufacturer to reduce the
perchloroethylene concentration in the drum to no more than 8600 ppm upon completion of
the drying cycle? Yes No.
XXIX. If no, the refrigerated condenser may need to be replaced.
23.5.5 Drying sensors shall extend the drying time in the drying cycle at least 4
minutes beyond the time that the solvent recovery rate is less than 40 ml/min or the
solvent concentration in the drum is less than 8600 ppm perchloroethylene;
Does the drying sensor extend the drying time in the drying cycle at least 4 minutes
beyond the time that the solvent recovery rate is less than 40 ml/min or the solvent
concentration in the drum is less than 8600 ppm perchloroethylene? Yes No
If no, repairs or maintenance is needed.
23.5.6 Refrigerated condensers on transfer machines, dry-to-dry machines that are not
closed-loop machines, and machines equipped with a door fan/local exhaust must be operated
with a diverter valve which prevents room air from passing through the condenser when the
door of the dry cleaning machine is open; and
XXXII. Is there a diverter valve that prevents room air from passing through the
condenser when the door of the dry cleaning machine is open? Yes No
XXXIII. If no, a diverter valve should be installed.
23.5.7 The machine operator shall record the temperature of the air-vapor stream
as measured by the temperature gauge at least one time-each calendar week
XXXIV. Does the operator record the temperature of the air-vapor stream as measured
by the temperature gauge at least one time-each calendar week? Yes No
XXXV. If no, that record keeping should be started.
23.6 Specifications for Door Fan/Local Exhaust Systems
Door fan/local exhaust systems operated pursuant to paragraph 23.4.2(b) of this
regulation shall adhere to the following requirements:
23.6.1 The door fan/local exhaust system must include a mechanical exhaust fan that is
activated when the loading door is open, drawing air from the machine drum to an exhaust
and causing room air to be drawn in through the loading door;
Does the door fan/local exhaust system must include a mechanical exhaust fan that is
activated when the loading door is open, drawing air from the machine drum to an exhaust
and causing room air to be drawn in through the loading door ? Yes No
If no, repairs or maintenance is needed.
23.6.2 A minimum inward air velocity of 100 fpm must be maintained through the door
opening area of the loading door of the machine. The velocity much be checked at least
once per week using a portable velometer or an equivalent device;
XXXVIII. Is there a minimum inward air velocity of 100 fpm through the door opening
area of the loading door
of the machine? Yes No
XXXIX. If no, repairs or maintenance is needed.
XL. Does the operator check and record the velocity weekly with a portable velometer or
equivalent device?
Yes No. If no, this should commence.
23.6.3 The door fan/local ventilation system must not recirculate vapors and must be
vented to the outdoor air;
XLI. Does the door fan/local ventilation system recirculate vapors ? Yes No
If yes, this should be fixed.
XLII. Is the door fan/local ventilation system vented to the outdoor air? Yes No
If no, this has to be changed so that it does vent to the outside air.
23.6.4 The door fan/local exhaust ventilation emissions must be controlled to a
design emission standard of 5 ppm perchloroethylene and an in-use maximum compliance
standard of 20 ppm;
XLIII. Is the door fan/local exhaust ventilation emissions control system designed
to have an emission standard of 5 ppm perchloroethylene and an in-use maximum compliance
standard of 20 ppm? Yes No. If no, this needs to be changed.
23.6.5 The owner or operator shall provide a sampling port in the exhaust ductwork that
is:
(a) Easily accessible;
(b) Downstream of any emissions control device;
(c) Upstream of any other inlet to the ductwork; and
(d) To the maximum extent possible, at least 8 stack or duct diameters downstream and
at least 2 stack or duct diameters upstream of any flow disturbance such as a bend,
expansion, contraction, or outlet in the ductwork, unless this is not possible given the
physical layout of the facility. If it is not possible to locate the sampling port 8 stack
or duct diameters downstream and 2 stack or duct diameters upstream of any flow
disturbance, the port should be located at a point as near to those parameters as
possible.
XLIV. Is there a sampling port in the exhaust ductwork that is:
(a) Easily accessible;
(b) Downstream of any emissions control device;
(c) Upstream of any other inlet to the ductwork; and
To the maximum extent possible, at least 8 stack or duct diameters downstream and at
least 2 stack or duct diameters upstream of any flow disturbance such as a bend,
expansion, contraction, or outlet in the ductwork, unless this is not possible given the
physical layout of the facility.
Yes No
If it is not possible to locate the sampling port 8 stack or duct diameters downstream
and 2 stack or duct diameters upstream of any flow disturbance, the port should be located
at a point as near to those parameters as possible.
23.6.6 The owner or operator of the facility shall measure the perchloroethylene
concentration in the exhaust stream weekly at the sampling port specified in subsection
23.6.5 using the following procedures:
(a) A colorimetric detector tube capable of measuring a concentration of 20 ppm to an
accuracy of ± 5 ppm shall be used;
Colorimetric detector tubes shall be used according to the manufacturer’s
instructions; and
XLV. Does the operator measure and record the perchloroethylene concentration in the
exhaust stream weekly at the sampling port? Yes No
If no, this should commence.
If a carbon adsorber is used to reduce the perchloroethylene concentration in the
exhaust stream, the measurement shall be performed just prior to a planned desorption of
the carbon adsorber.
XLVI. Is there a carbon adsorber to
reduce the perchloroethylene concentration in the exhaust stream? Yes No
If yes the measurement shall be performed just prior to a planned desorption of the
carbon adsorber.
23.7 Requirements for Carbon Adsorbers
For 4th Generation machines:
23.7.1 A secondary carbon adsorber operated to comply with subsection 23.4.1 or
paragraph 23.4.2(a) of this regulation shall adhere to the following requirements:
The carbon adsorber must be designed to function with a refrigerated condenser
complying with the specifications in section 23.5 of this regulation;
XLVII. Is the carbon adsorber designed to function with a refrigerated condenser
complying with the specifications in section 23.5 of this regulation? (check operation
manual) Yes No
The carbon adsorber must reduce the perchloroethylene concentration in the drum to 300
ppm or less;
XLVIII. Does the carbon adsorber reduce the perchloroethylene concentration in the
drum to 300 ppm or less? Yes No
If no, repairs or maintenance is needed.
The dry cleaning control system must be designed so that the gas-vapor stream passes
through the secondary carbon adsorber after the final cool-down cycle and immediately
before the machine door is opened;
XLIX. Has t he dry cleaning control
system been designed so that the gas-vapor stream passes through the secondary carbon adsorber after the final cool-down cycle and
immediately before the machine door is opened? Yes No. (check manual)
The carbon adsorber system must use non-contact steam or hot air for desorption, and
must be desorbed in accordance with the manufacturer’s instructions or weekly,
whichever is more frequent; and
Does The carbon adsorber system use non-contact steam or hot air for desorption?
Yes No.
LI. Is the carbon desorbed in accordance with the manufacturer’s instructions or
weekly, whichever is more frequent? Yes No. If no, this should start.
Desorption dates should be recorded to document compliance with this section.
(e) The owner or operator shall measure the perchloroethylene concentration in the drum
weekly according to the following
specifications:
(1) Measurements shall be made using a colorimetric detector tube designed to measure a
concentration of 300 ppmv of
perchloroethylene to an accuracy of ±75 ppmv;
(2) Colorometric detector tubes shall be used according to the manufacturer’s
instructions; and
Measurements shall be taken immediately upon opening the door of the dry cleaning
machine at the end of the drying cycle in the space above the articles.
LII. Does the owner have colorimetric tubes and a pump that will detect 300 ppmv
perc, ±75 ppmv? Yes No.
LIII. Are the tubes used according to the manufacturer’s instructions?
Are the measurements taken immediately upon opening the door of the dry cleaning
machine at the end of the drying cycle in the space above the articles?. Yes No.
When the measurements are taken, are they less than 300 ppmv?
Yes No.
If no, repairs or maintenance is needed.
23.7.2 First or Second generation machines: A primary carbon adsorber operated
to comply with subsection 23.4.3 shall adhere to the following specifications:
The perchloroethylene emissions from the carbon adsorber shall not exceed 20 ppmv at
any time;
LVI. Is the outlet from the carbon absorber tested weekly and recorderd? Yes No.
LVII. Do the perc emission exceed 20 ppmv? Yes No. if yes, carbon needs to be desorbed.
(b) The dryer exhaust, washing door loading vents, water separator vents, and floor
vents shall be ducted to the carbon adsorber. If distillation units and storage tanks are
equipped with exhaust systems, these exhausts must also be ducted to the carbon adsorber;
Are all of the following items ducted to the carbon adsorber?
Dryer exhaust? Yes No
Washing door loading vent? Yes No
Water separator vent? Yes No
Floor vent? Yes No
Distillation unit exhaust? Yes No
Storage tank vent? Yes No
(c) The carbon adsorber shall not be bypassed or shut down at any time while articles
are being processed in the dry cleaning system;
Is the carbon adsorber ever bypassed or shut down while the dry cleaning system in
operation?
Yes No.
desorption must be performed with a steam pressure that conforms to the
manufacturer’s specifications;
Is the desorption done according to the manufacturer’s specifications?
Yes No
No bypass to the atmosphere shall be permitted during the steam phase of the desorption
cycle;
LXI. Is there a bypass to the atmosphere during the steam phase of the desorption
cycle?
Yes No. If yes, this should be corrected.
(f) The owner or operator shall provide a
sampling port in the carbon
adsorber exhaust ductwork which is:
(1) Easily accessible;
(2) At least 8 stack or duct diameters downstream and at least 2 stack or duct
diameters upstream of any flow disturbance such as a bend, expansion, contraction, or
outlet; and
Upstream of any other inlet to the ductwork; and
LXII. Is there a sampling port in the exhaust ductwork that is:
(a) Easily accessible;
(b) Downstream of any emissions control device;
(c) Upstream of any other inlet to the ductwork; and
At least 8 stack or duct diameters downstream and at least 2 stack or duct diameters
upstream of any flow disturbance such as a bend, expansion, contraction, or outlet in the
ductwork.
Yes No _________
(g) The owner or operator of the facility shall measure the perchloroethylene
concentration in the exhaust stream weekly at the sampling port specified in paragraph 23.6.7(f) using the following procedures:
(I) A colorimetric detector tube capable of measuring a concentration of 20 ppm to an
accuracy of ± 5 ppm shall be used;
Colorimetric detector tubes shall be used according to the manufacturer’s
instructions; and
Does the operator have colorimetric tubes and a pump that can measure a
concentration of 20 ppm to an accuracy of ± 5 ppm ?
Yes No
Does the operator have the manufacturer’s instructions for the colorimetric tubes?
Yes No
Does the operator take weekly samples and record them?
Yes No
The measurement shall be performed just prior to a planned desorption of the carbon
adsorber.
Are the measurements taken just prior to a planned desorption?
Yes No
23.8 Requirements for Vapor Barriers and General Exhaust Ventilation
All co-located stores that open after December 2, 2003 need a vapor barrier
Any co-located perchloroethylene dry cleaning facility that begins operation after
December 2, 2003 shall be equipped with the following before beginning operation:
LXVII. Is the store co-located and opened after December 2, 2003? If yes, a vapor
barrier is needed.
(a) A vapor barrier that encloses the dry cleaning machine(s) or the room where the dry
cleaning machine is located. The vapor barrier shall adhere to the following
specifications:
(1) The vapor barrier shall be constructed of 22 mil thick PVC, sheet metal, glass,
metal foil face composite board, Structoglas Class C/Ill Wall and Ceiling Panels (minimum
thickness 0.085 inch) or another material approved by the New York Department of
Environmental Conservation as impermeable to perchloroethylene vapors;
(2) The vapor barrier shall be constructed in a manner consistent with applicable fire
codes, as determined by fire
code enforcement agencies;
(3) The vapor barrier shall be constructed and maintained such that all joints, seams
and openings, except for make-up air
and exhaust openings and entry doors, are sealed.
(4) Cement floors in the vapor barrier must be coated with an epoxy Novolac coating or
another coating approved by the New York Department of Environmental Conservation for this
purpose;
(5) The vapor barrier shall be maintained such that it continues to be
impermeable to perchloroethylene vapors at all times;
and entry doors shall be kept closed except when a person is entering or
exiting the room enclosure; and
LXVIII Is the vapor barrier built according to the above requirements? Yes No. If no,
need to
make changes.
A general exhaust system that is completely separate from the ventilation system(s)
serving other areas of the building. The intake of the general exhaust ventilation system
must be located near the dry cleaning machinery or connected to the exhaust from the room
enclosure and the system must exhaust emissions to the outdoor air. The exhaust system
must be operated at all times that the dry cleaning machine(s) is in operation and during
maintenance operations and must produce at least one air change per five minutes.
Does the vapor barrier room have an exhaust system that changes the air once every 5
minutes?
23.8.2 A co-located perchloroethylene dry cleaning facility that began operation before
December 2, 2003 shall, by the dates specified in subsection 23.8.3, operate a general
exhaust system according to the specifications in
23.8.1(b) and either
(a) Operate no perchloroethylene dry cleaning machine that is not a closed-loop
dry-to-dry machine equipped with a refrigerated
condenser, a secondary carbon adsorber and a drying sensor, or
Install a vapor barrier that meets the specifications in subsection 23.8. 1(a).
LXX. If a store is co-located and opened before December 2, 2003, a 4th generation
machine
or a vapor barrier is needed.
23.8.3 Compliance with subsection 23.8.2 is required according to the following
schedule:
A perchloroethylene dry cleaning facility that is co-located with a
residence, a school, a day care center or a business that sells food or food products
shall be in compliance with subsection 23.8.2 on and after December 2, 2004 or on and
after the date 12 months after the facility is first co-located with a residence, school,
day care center or business that sells food or food products, whichever is later. In no
case shall the compliance date be later than December 2, 2007.
If the dry cleaning store is co- located with a residence, school, day care center, or
food store, a 4th generation machine or a vapor barrier is required by December 2, 2004.
If the dry cleaning store is preexisting, and then becomes co located with a residence,
school, day care center or food store, the store has 12 months to install a 4th generation
machine or a vapor barrier. December 2, 2007 is the latest date for this requirement.
(b) All other co-located perchloroethylene dry cleaning facilities
shall be in compliance with subsection 23.8.2 on and after December 2,
2007.
LXXIII. All other co located dry cleaning stores shall have a 4th generation machine
or a vapor barrier by December 2, 2007
23.9 Stack Requirements
23.9.1 Perchloroethylene-containing air exhausted from dry cleaning systems must be
vented through a vertical stack that extends at least 6 feet above the building’s
roof line.
LXXIV. If there is a stack for the exhaust of perc vapors, is the stack at least 6 feet
above the roof? Yes, No. If the building is higher than 2 stories, the store can apply for
an exemption to this.
23.9.2 The exhaust stack must not be equipped with a cap, elbow or other device
that would interfere with the vertical discharge of the exhaust.
LXXV. It is not allowed to have anything on the stack that would interfere with the
vertical exhaust.
23.9.3 The Director may require that a stack be extended higher than 6 feet or that the
location of a stack on a roof be changed if he determines that the location of the stack
discharge may cause excessive perchloroethylene exposure to neighbors, neighboring
facilities or to other occupants of the building in which the dry cleaning facility is
located.
LXXVI. The Director can require a higher stack to protect the neighbors.
23.9.4 Facilities located in buildings that are higher than two stories may apply to
the Director for an exemption to subsection 23.9.1.
23.10 Emergency Release Prevention and Response Requirements
23.10.1 Any dry cleaning machine installed after December 2, 2003 shall be equipped
with a spill containment system capable of containing 125 percent of the capacity of the
largest perchloroethylene-containing tank or vessel in the facility.
LXXVII. Was the dry cleaning machine installed after December 2, 2003? Yes No. If yes,
a spill pan is needed and the spill pan should be 125% of the largest tank in the
machine.
23.10.2 On and after June 2, 2003, the owner or operator of dry cleaning equipment
installed before December 2, 2003 shall ensure that:
(a) Floor drains and flooring in the vicinity of the dry cleaning equipment are sealed
so as to be impermeable to perchloroethylene spills; or
Dikes, berms or other containment devices sufficient to prevent spilled
perchloroethylene from reaching floor drains and permeable flooring have been placed in
areas where spills are most likely to occur and procedures for preventing spill migration
have been established and are followed.
Was the dry cleaning machine installed before December 2, 2003?
Yes No
If yes, floor drains and permeable floors have to be sealed or dikes or berms have to
be
constructed to protect the floor drains or permeable floors. Proceedures to prevent
spill migrations have to be
written and followed.
23.10.3 In the event of a perchloroethylene spill, the owner or operator of the
facility must take all reasonable measures to ensure that liquid perchloroethylene is not
released to the environment. These measures shall include, where applicable, but are not
limited to:
(a) Ceasing operation of dry cleaning machines;
(b) Increasing room exhaust ventilation;
(c) Collecting and containing spilled liquid perchloroethylene;
(d) Removing and maintaining containers of collected perchloroethylene in a safe
manner; and
Notifying co-located businesses and/or residences that a spill has occurred.
LXXIX. If there is a spill, all of the above steps should be done if needed,
or more.
23.10.4 The facility owner or operator must notify the Department and appropriate
state, county or municipal emergency response agencies immediately in the event of a fire,
explosion, or a spill that results in the release of liquid perchloroethylene to the
environment.
If there is a fire or explosion or spill that causes a release of perc, the
department and emergency response agencies must be notified.
RIDEM phone #:_______________
Emergency response agency:_________________________________,
phone:_______________________
Emergency response agency:_________________________________,
phone:_______________________
Emergency response agency:_________________________________,
phone:_______________________
23.10.5 The following information must be recorded for each explosion, fire, or
perchloroethylene spill:
(a) The date, time, duration and nature of the incident;
(b) Whether the incident resulted in a release of liquid perchloroethylene to the
environment;
(c) Agencies notified, and the dates and times of the notification; and
Corrective actions taken.
LXXX. Does the owner have record keeping forms for emergency incidents? Yes No
23.11 General Requirements for Perchloroethylene Dry Cleaning Facilities
23.11.1 Dry cleaning systems shall be operated and maintained according to the
manufacturer’s specifications and recommendations.
LXXXI. Does the operator have manufacturer’s manual for operation of the machine?
Yes No
LXXXII. If yes, is the machine operated according to the recommendations?
23.11.2 Washer/extractor and reclaimer doors on transfer machine systems and the
doors on dry-to-dry machines shall be kept closed except when necessary for maintenance of
the equipment or when articles are being loaded or unloaded;
LXXXIII. Are the doors on the machines closed at all times(except for maintenance and
loading/unloading)? Yes No
23.11.3 Filtration cartridges must be drained in the filter housing for at least 24
hours or vented to the control device before disposal.
LXXXIV. Are the filtration cartridges drained in the filter housing for at least 24
hours or vented to the control device before disposal? Yes No
23.11.4 All perchloroethylene and perchloroethylene-containing waste must be stored
in sealed containers with no perceptible leaks.
LXXXV. Are all perchloroethylene and perchloroethylene-containing waste must be
stored in sealed containers with no perceptible leaks? Yes No.
23.11.5 The owner or operator of a dry cleaning facility shall inspect the facility for
perceptible leaks at least once per week while the dry cleaning system is operating.
Liquid leaks shall be detected by visual inspection for pools or droplets of liquid. Vapor
leaks shall be detected using a portable halogenated hydrocarbon detector. The following
components must be included in the weekly inspection if present at the facility:
(a) Hose and pipe connections, unions, couplings and valves;
(b) Machine door gaskets and seatings;
(c) Filter head gaskets and seatings;
(d) Pumps;
(e)Solvent tanks and storage containers;
(f) Water separators;
(g) Muck cookers;
(h) Distillation units;
(i) Cartridge filter housings;
(j) Diverter valves; and
Exhaust dampers.
Does the owner or operator of a dry
cleaning facility inspect the facility for perceptible leaks at least once per week while
the dry cleaning system is operating? Liquid leaks shall be detected by visual inspection
for pools or droplets of liquid. Vapor leaks shall be detected using a portable
halogenated hydrocarbon detector. The above components must be included in the weekly
inspection if present at the facility.
Does the owner have a halogenated hydrocarbon detector? Yes No
Does the owner maintain records of the weekly leak detecting? Yes No
23.11.6 All leaks of perchloroethylene liquid or vapor must be repaired immediately
upon detection if no new parts are needed or if replacement parts are available at the
facility. If parts are needed and are not available at the facility, a purchase order for
those parts shall be issued within 2 working days. Repair parts shall be installed within 5
working days of receipt.
LXXXIX. Are any leaks repaired immediately? Yes No
XC. If not, are parts ordered within 2 days? Yes No
XCI. Are repairs completed within 5 days? Yes No
23.11.7 If parameter values monitored pursuant to the requirements in subsections
23.5.7, 23.6.6,23.7.1(e) or 23.7.2 (g) exceed the allowable levels specified in
subsections 23.5.1, 23.6.4, 23.7.1(b) or 23.7.2(a), respectively, adjustments or repairs
shall be made to the dry cleaning system to meet those limits. All repairs must be done
immediately if no parts are needed or if replacement parts are available at the facility.
If parts are needed and are not available at the facility, a purchase order for those
parts shall be issued within 2 working days. Repair parts shall be installed within 5 working
days of receipt.
23.11.8 Any liquid perchloroethylene that is drained from water separators on
reclaimers, dry-to-dry units or carbon adsorbers must be collected using one of the
following methods:
(a) The liquid shall be drained through a collection tube into containers which have a
single small hole for the collection tube and which do not have other gaps or holes; or
The liquid shall be drained directly to a storage tank.
XCII. Is liquid perc drained according to the above?
23.11.9 Fugitive perchloroethylene emissions from any part of a dry cleaning system
must not exceed 50 ppm, as measured with a colorimetric detector tube, at any time, except
during short-term maintenance operations involving the opening of dry cleaning system
components for inspection or repair.
XCIII. Are there any fugitive perc emissions exceeding 50 ppm? If yes, they must be
repaired.
23.12 Reporting and Record Keeping
23.12.1 The owner or operator of a perchloroethylene dry cleaning facility shall retain
onsite a copy of the design specifications and the operating manuals for each dry cleaning
system located at the facility.
XCIV. Are the design specs and operating manuals on site?
23.12.2 The owner or operator of a perchloroethylene dry cleaning facility shall
maintain the following records in a readily accessible location for at least 5 years
and shall make these records available to the Department upon verbal or written request:
(a) A log of perchloroethylene purchases, the date of those purchases, and the receipts
for those purchases;
(b) The number of loads dry cleaned each calendar month;
(c) The dates of weekly inspections conducted pursuant to the requirements in
subsection 23.11.5, the locations where perceptible leaks were detected during each
inspection, copies of purchase orders issued for parts to repair the leaks, and the dates
that the leaks were repaired;
(d) The dates when desorption of a carbon adsorber occurred;
(e) A record of control equipment maintenance, including the replacement of carbon in a
carbon adsorbers;
(f) The temperatures recorded pursuant to
the requirements in subsection 23.5.7, the dates that those temperatures were recorded
and, if a temperature exceeded 450F, copies of the purchase orders issued for repair
parts, if applicable, and the date that the dry cleaning equipment or dry cleaning control
equipment was repaired;
(g) The colorimetric tube concentrations measured pursuant to the requirements in
subsection 23.6.6 and paragraph 23.7.2(g), the dates that those concentrations were
measured and, if a concentration exceeded 20 ppmv, copies of the purchase orders issued
for repair parts, if applicable, and the date that the dry cleaning equipment or dry
cleaning control equipment was repaired;
(h) The colorimetric tube concentrations measured pursuant to the requirements in
subsection 23.7.1(e), the dates that those
concentrations were measured and, if a concentration exceeded 300ppmv, copies of
purchase orders issued for repair parts, if applicable, and the date that the dry cleaning
equipment or dry cleaning control equipment was repaired; and
(i) The records of fires, explosions and spills specified in subsection 23.10.5
XCV. Are the above records kept on site? Yes No
23.13 Severability
If any provision of this regulation, or the application thereof to any person or
circumstances, is held invalid by a court of competent jurisdiction, the validity of the
remainder of the regulation shall not be affected thereby
23.14 Effective Date
The foregoing Regulation, "Control of Perchloroethylene Emissions from Dry
Cleaning Operations," as amended, after due notice, is hereby adopted and filed with
the Secretary of State this 12th day of November 2003 to become effective twenty days
after filing, in accordance with the provisions of Chapter 23-23, "Air
Pollution," of the General Laws of Rhode Island of 1956, as amended.
|