Loading...
HomeMy WebLinkAbout20111206DryCleanSpot_RPT 1 NORTH CAROLINA DIVISION OF WASTE MANAGEMENT Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program Initial Inspection Report Date: 12/22/2011 Facility Identification Dry Clean Spot Facility ID: 920071C EPA Generator ID: County/FIPS: Wake / 92 DSCA Cleanup ID: N/A Facility Data Dry Clean Spot 1142 N. Main St. Fuquay Varina, NC 27526 Lat: 35.591670 Long: -78.782692 SIC: 7216 / Dry Cleaning Plants, Except Rugs NAICS: 81232 / Dry Cleaning and Laundry Services (except Coin-Operated) Date of Facility Establishment: 2008 Compliance Data Inspection Date: 12/6/2011 Time In: 10:45 am Time Out: 12:25 pm Inspector(s): Pam Moore Operating Status: OO / Operating Compliance Code(s): M / In Violation of MMPs Action Code: 10 / Initial Inspection Contact Data Classification Data Solvent: Ecosolv System: Transfer Installation Date: 2008 Installation Category: N/A Consumption Category: N/A HW Generator Status: N/A DSCA Site Number: N/A Facility Contact Nick Patel 1142 N. Main St. Fuquay Varina, NC 27526 919-557-4800 Facility Owner Nick Patel 1142 N. Main St. Fuquay Varina, NC 27526 919-557-4800 Property Owner Blalock Properties 6741 Rock Service Station Rd. Raleigh, NC 27603 Inspector’s Signature: Pam Moore Date of Signature: Comments: No spill containment under solvent drum and waste solvent drum, and no waste manifests on site were repeat violations. (I) DIRECTIONS: From Tillery Place, go southeast on Tillery Place and turn right onto Capital Blvd/US-401S. Continue to follow US-401 S for 18.6 miles. US-401 S becomes Main Street in Fuquay Varina. The facility is on the left. (II) FACILITY HISTORY: Dry Clean Spot was established by Mr. Nick Patel in January 2008 as a petroleum facility. Mr. Chris Ramji of Dry Clean City set up the facility for Mr. Patel. The facility is open from 7:00 a.m. to 7:00 p.m. Monday through Friday and from 8:00 a.m. to 5:00 p.m. on Saturday. The facility is located in a shopping center and is conjoined with a mattress store and a consignment clothing store. The facility does not service any pickup stores. Solvent History: Solvent: Dates Used: Petroleum 2008 to present Previous Inspections: Date Visit Type Violation Type(s) Worst Violation(s) Action Taken Response Due Recvd Date Inspector 08/11/09 Outreach Training Visit MMP Spill containment Recordkeeping CAL on 08/19/09 09/08/09 None Jason Gill Sarah Gornick Previous Releases, Events or Complaints: None DSCA Sampling: None. 2 (III) FACILITY CLASSIFICATION: Because Dry Clean Spot uses as petroleum based dry cleaning machine, there is no facility classification. NEW STATIONARY PERFORMANCE STANDARDS (NSPS) CATEGORY: The dry cleaning machine was installed after December 14, 1982 and the facility’s total drying capacity is more than 84 lbs.; therefore, Dry Clean Spot is subject to NSPS Subpart JJJ regulations. Dry Cleaning Equipment Summary Machine Number Type of Machine Manu- facturer Model # Serial # Date (yr) of manufacture Date (year) Of Installation Solvent used Observed Operating? 1 Washer Marvel Petrol Dry PS-65 PS650017 Unknown 1/2008 Ecosolv yes 2 Reclaimer Marvel Petrol Dry PC-55 PC550039 Unknown 1/2008 Ecosolv yes 3 Reclaimer Marvel Petrol Dry PC-55 PC550040 Unknown 1/2008 Ecosolv yes HAZARDOUS WASTE GENERATOR CATEGORY – N/A: The facility uses a solvent (Ecosolv) that is not classified as hazardous and does not generate hazardous waste. The flash point for the solvent being used is 142°F. Contact water is treated in an onsite wastewater treatment unit (WWTU). (IV) INSPECTION SUMMARY: On December 6, 2011, Pam Moore, Compliance Inspector with the North Carolina Division of Waste Management, Dry Cleaning Solvent Cleanup Act (DSCA) Program, conducted a compliance inspection at Dry Clean Spot (picture 1). Mr. Viral Patel, facility attendant (owner’s son), was on site during the visit and provided the inspector access to the facility equipment, solvent and waste solvent storage areas and available records. The facility utilizes a petroleum transfer dry cleaning system consisting of one washer and two solvent recovery dryers. The washer is a Marvel PS-65 machine (picture 2). Two Marvel PC-55 (55-lb. capacity) reclaimers (picture 3) are used. A filter assembly (picture 4) consisting of three housings that can hold a total of twelve split filters and six carbon filters is utilized. The washer is in one spill containment unit, the two reclaimers are in one spill containment unit and the filter assembly is in one spill containment unit. The dry cleaning system is operated from 7:00 a.m. to about noon Monday through Friday and processes from five to eight loads per day. The system was observed in operation. No perceptible leaks were observed by the inspector. Separator water from the reclaimers was collected in containers located within the spill pan of the reclaimers (picture 5). Mr. Patel stated that about 3 gallons of separator water is generated total from both dryers per day. The separator water is treated in an onsite wastewater treatment unit. A log of the solvent filter changes (picture 6) is attached to the wall next to the filter assembly. The filters are changed in rotation (September 30, 2011, November 2, 2011, November 14, 2011) and Mr. Patel said the filters are drained for a week prior to removal and disposal in the waste drum. A 55-gallon drum of Ecosolv was stored behind the washer without spill containment (picture 7). Ms. Moore told Mr. Patel that the solvent drum must be in spill containment with a capacity of 60.5 gallons or more. A Galaxy Mister (picture 8) wastewater treatment unit (WWTU) is used to treat facility generated contact water. The WWTU is located within the spill pan of the reclaimers. The discharge piping is routed through the ceiling. Mr. Patel stated that the filters on the WWTU are changed every two to three months, but a filter change log is not being kept. However, the inspector noted that a date, 2/9/11, was written on the filter case of the WWTU. Mr. Patel stated the filters had been changed since that date and did not know why the date had been written on the case. With the estimate of three gallons of separator water generated per day, approximately 720 gallons of separator water is generated per year. The manufacturer recommends changing the filters on the Galaxy Mister every 400 gallons or once per year, whichever comes first. Ms. Moore told Mr. Patel that it was important to keep a log documenting the amount of water treated in the WWTU and the dates of the filter changes to be sure the filters were being changed in accordance with the manufacturer’s recommendations. The spent filters are disposed in the waste drum. A 55-gallon waste drum (picture 9) is located outside behind the facility in a locked area. The waste drum does not utilize secondary containment and was not labeled. The drum was tightly closed but the locking band was not attached to the lid. Mr. Patel said the drum was about 1/3 full. The facility contracts with MCF Systems of Atlanta for disposal of the waste drum. Mr. Patel said the waste drum is picked up once per month but is only a third to a half full each month. The waste drum is used for the disposal of spent solvent filters, spent WWTU filters and spotting table waste. The clothes press vacuum pump (picture 10) is located in the boiler room. Pump condensate is drained into a collection bucket and treated in the Galaxy Mister WWTU. The 5-gallon collection bucket was full at the time of the inspection and the inspector advised Mr. Patel to empty the bucket before it overflowed onto the floor. Mr. Patel stated that one gallon of condensate is generated about every other day. 3 The spotting table (picture 11) is located in front of the dry cleaning system and is equipped with a waste collection container. Mr. Patel stated that very little waste is generated and that the waste container is periodically emptied into the waste drum. Waste manifests for the last three years were not available on site for review. Mr. Patel said his father, Nick Patel, likely had the manifests at his home office. Ms. Moore told Mr. Patel that the manifests are required to be on site. The operation manuals for the washer and reclaimers were on site, emergency spill cleanup materials were on site, and an emergency information form (picture 12) was completed and posted on site. Material Safety Data Sheets (MSDS) for Ecosolv and the spotting agents were on site. The MSDS were in several locations and Ms. Moore suggested that Mr. Patel organize them in one place for ease of review. The following is a summary of Dry Clean Spot’s compliance with respect to the DSCA Required Minimum Management Practices provided in 15A NCAC 02S.0202, and Standards of Performance for Petroleum Dry Cleaners found in 40 CFR Part 60 Subpart JJJ. MMP VIOLATIONS: 15A NCAC 02S .0202 1. Wastewater treatment equipment records for last 3 years not available. 2. Waste manifests for last 3 years not available. 3. Solvent drum not in spill containment. 4. Waste drum not in spill containment. (V) CONCLUSIONS: Dry Clean Spot received an outreach visit on August 11, 2009. No response was received to the corrective action letter issued on August 19, 2011. The facility received an initial compliance inspection on December 6, 2011. Carbon copies of the DSCA compliance checklist were left at the facility, one for their records and one to be returned with their response to the DSCA office by December 27, 2011. Mr. Viral Patel signed for the checklist. Several repeat violations were noted, including the solvent drum not located in spill containment and no waste manifests on site. Based on observations documented by the DSCA inspector, Dry Clean Spot was in violation of the following regulations: MMP – 15A NCAC 02S .0202 (b)(1) Wastewater treatment equipment records for last 3 years not available (b)(1) Waste manifests for last 3 years not available (b)(2) Spill containment not installed under solvent storage area (b)(2) Spill containment not installed under waste solvent storage area (VI) ENFORCEMENT HISTORY (NOVs, NREs, PENALTIES): None (VII) RECOMMENDATIONS: DSCA supervisors will determine if a Notice of Violation (NOV) will be issued to Mr. Nick Patel or if enforcement and civil penalties are warranted after reviewing a written response from Dry Clean Spot to the compliance checklist. A follow up inspection should be conducted within 6 months to confirm compliance.