EPA does not intend to require TRI reporting from small dry cleaning facilities with this rule. In the past, EPA has occasionally opted to extend TRI coverage only to a portion of a sector. For example, TRI coverage of Electric Utilities (NAICS 2211) is limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce. EPA is considering adopting a limitation that would indicate explicitly that this rule adds only large dry cleaning facilities and exempts smaller facilities. If deemed appropriate, how should the limitation be defined?
Notably, the TRI “otherwise use” threshold of 10,000 pounds would inherently focus the rule only on large facilities and not require TRI reporting by smaller facilities. EPA estimates that a facility would need to use in excess of 700 gallons of PCE to exceed the otherwise use threshold, an amount EPA believes to be used only by large facilities. Given this information, is an explicit limitation to the addition of this sector necessary, or would small facilities be able to determine easily that they did not trigger thresholds and were therefore not required to report under TRI?