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Revised Rural Area Flexibility Analysis 6 NYCRR Parts 232 and 200

1. Types and estimated numbers of rural areas:

The New York State Department of Environmental Conservation (Department) is proposing to repeal and replace existing 6 NYCRR Part 232, entitled "Perchloroethylene Dry Cleaning Facilities" to: update outdated provisions; add new components to improve compliance and program delivery; and address advancements in technology and the industry regarding the use of alternative dry cleaning equipment.

There are no requirements in the proposed regulation which apply only to rural areas. The proposed changes apply to all dry cleaning facilities using perc or an alternative solvent throughout New York State. With less than 10% of all dry cleaners located outside the New York City, Long Island and lower Hudson Valley area, this proposal will have a small impact on rural areas.

2. Reporting, record keeping and other compliance requirements; and professional services:

There are no specific requirements in the proposed regulations which apply exclusively to rural areas. This rulemaking imposes new paperwork, record keeping and reporting requirements on dry cleaning facility owners and dry cleaning equipment manufacturers or vendors regardless of whether they are located in a rural area or not. The regulation requires owners of co-located perc dry cleaning facilities, or their representatives, to test perc dry cleaning machines, monthly, for end of cycle perc drum concentrations and record those readings on a department provided form. The regulation also requires manufacturers of new uncertified models of perc dry cleaning machines that are proposed to be installed in New York State to issue a notarized Statement of Compliance affirming that the model was tested and found to comply with all design and performance standards in the revised regulation.

The regulation will require alternative solvent dry cleaning facility owners to post notices, supplied by the Department, informing the public of the regulated alternative solvent chemicals being used at the facility. Owners will also be required to keep records of solvent purchases, leak inspections, emergency response and corrective action, and required operation and maintenance activities. These records must be retained on-site for at least five years. Facilities will also have to retain, on-site, a copy of the design specifications and operating manual for each dry cleaning system and emission control device located at the dry cleaning facility.

3. Costs:

Repeal and replacement of existing Part 232 will impose additional costs on individual business owners. No additional cost is attributed to manufacturers for required machine testing because they already test their machines for compliance with equipment standards and required control efficiencies.

Business owners/operators at the 1,007 non-major, co-located perc dry cleaning facilities, throughout New York State, will be required to test their fourth generation perc dry cleaning machines, once each month, for perc drum concentrations at the end of the dry cleaning cycle. Owners will have to purchase a $400 air sampling pump and single use colorimetric sampling tubes, costing about $7 apiece, in order to conduct the required testing. If a measured end of cycle perc drum concentration exceeds the allowable limit, the regulation requires the source owner to have the machine repaired and brought into compliance.

The 17 business owners that are still operating the 22 third generation perc dry cleaning machines will have to discontinue operation of these machines prior to December 31, 2021. Those at co-located residential locations will have to discontinue operation by December 21, 2020 due to the existing future federal ban on the use of perc dry cleaning machines at such facilities. Phased-out third generation perc dry cleaning machines may be sold out of state or properly disposed of as scrap metal. To continue in business, owners would have to purchase and install new or "like new" compliant alternative solvent machines, new compliant perc dry cleaning machines or wet cleaning equipment.

Although not a result of this proposed rulemaking and due to the future federal ban discussed above, all 315 co-located residential perc dry cleaners (approx. 315 statewide, 290 of which are in New York City) will be required to purchase and install wet cleaning equipment or alternative solvent dry cleaning equipment, become drop shops or, alternatively, shut down prior to December 21, 2020.

New compliant fourth generation perc dry cleaning machines typically cost between $25,000, for a 25 pound machine, and $90,000, for a 90 pound machine. These machines are only available by special order and require a 50% down payment. Equipment removal costs for retired equipment range from $1,000 to $7,000.

The ten facility owners still operating alternative solvent transfer equipment must phase-out: all dip tanks, drying cabinets, vented waterproofing operations and uncontrolled dryers by December 31, 2021; solvent recovery dryers that are controlled with a water cooled condenser by December 31, 2026; and all remaining alternative solvent transfer machines by December 31, 2031. Should these facilities wish to continue dry cleaning operations on-site, they must purchase compliant equipment. All phase-out dates are after the "typical" 15 year useful life of the equipment.

New compliant alternate solvent dry cleaning machines, without a still, cost between $32,000, for a 25 pound machine, and $100,000, for a 90 pound machine. New compliant alternative solvent dry cleaning machines therefore only cost approximately 10 percent more than new compliance fourth generation perc dry cleaning machines. Stills are recommended by the National Cleaners Association (NCA) for solvent recovery and quality cleaning purposes and range in price from $12,000 to $23,000.

Outside of New York City, automatic sprinkler systems are not required by the state fire code for alternative solvent machines equipped with integrated fire extinguishing systems and/or safety features that minimize the fire/explosion risk. Consequently, the higher compliance costs, outlined above, for NYC dry cleaners are conditioned upon the current NYC fire code and could therefore change before the December 21, 2020 federal ban goes into effect.

The cost of physical installation for both perc and alternative solvent machines can range from $2,500 to $5,500 and concrete machine pads cost from $2,500 to $3,000. Outside of New York City, engineering and permitting fees range from $3,500 to $5,000.

A typical owner would need to spend about $47,000 for professional wet cleaning equipment; this includes a washer, dryer and tensioning forms necessary to restore original clothing shape. Installation costs are normally between $2,000 and $2,500 and are, therefore, less expensive than installing perc or alternative solvent dry cleaning equipment. Wet cleaning operational costs are also generally lower than those for perc or alternative cleaning methods. Automatic sprinklers are not required. Therefore, switching to wet cleaning is a viable option for facilities that are looking to minimize their compliance costs.

4. Minimizing adverse impact:

The proposed changes will not adversely impact rural areas.

5. Rural area participation:

The Department plans on holding public hearings at various locations throughout New York State once the regulation is proposed. There will be a public comment period in which interested parties can submit written comments.

  • Contact for this Page
    Division of Air Resources
    Part 232
    625 Broadway
    Albany, NY 12233-3254
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