20121018DryCleanSpot_RPT

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NORTH CAROLINA DIVISION OF WASTE MANAGEMENT
Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program
Inspection Report
Date: 10/18/2012

Facility Identification
Dry Clean Spot
Facility ID: 920071C
EPA Generator ID:
County/FIPS: Wake/183
DSCA Cleanup ID:
Facility Data
Dry Clean Spot
1142 N Main St.
Fuquay-Varina, NC 27526-2613
Lat: 35.59167 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: 10/18/2012
Time In: 10:15 AM Time Out: 11:25 AM
Inspector(s): Jack Kitchen
Operating Status: OO/Operating
Compliance Codes: In Compliance
Action Code: 01/Inspection
Contact Data Classification Data
Service Type: Full Service (Active)
Solvent: Ecosolve
System: Transfer
Installation Date: 2008
Installation Category: N/A
Consumption Category: N/A
HW Generator Status: N/A
Facility Contact
Ms. Patricia Hilliard or
Mr. Nick Patel
1142 N. Main St.
Fuquay-Varina, NC
27526
[phone]

Facility Owner
Mr. Nick Patel
1142 N. Main St.
Fuquay-Varina, NC
27526
[phone]
[phone]
Property Owner
Blalock Properties
1148 N. Main St.
Fuquay-Varina, NC
27526
[phone]
Inspector’s Signature:
Date of Signature: October 24, 2012

Comments:
In Overall Compliance

(I) DIRECTIONS: From the DSCA office at Green Square located in Raleigh, travel south on Capital Blvd. Capital
Blvd. becomes US-401. Travel 19 miles on US-401 until it becomes Main St. in Fuquay-Varina. The facility is located in
a small shopping center on the left.

(II) FACILITY HISTORY: The Dry Clean Spot was established by Mr. Nick Patel in January 2008 as a full service
petroleum dry cleaning plant. Mr. Chris Ramji of Dry Clean City assisted Mr. Patel with the opening the facility. 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 small shopping center and is conjoined with a mattress store on the right and a clothing store on the
left. The facility does not dry clean garments for other pickup stores.

Solvent History:
Solvent Dates Used
Ecosolve /DF2000 2008 to Present

Previous Inspections:
Date Visit Type Violation
Types
Worst
Violation(s)
Action Taken Response
Due
Received
Date
Inspector
12/6/2011 Initial
Inspection
MMP Spill Containment NOV sent on
2/14/2012
3/6/2012 3/6/2012 Pam Moore
CHKLST sent
on 12/6/2011
12/27/2011 12/29/2011
8/11/2009 Outreach
Training Visit
MMP Spill Containment
Recordkeeping
CAL sent on
8/19/2009
9/8/2009 None Sarah
Gornick

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Complaints: None

DSCA Sampling: None

(III) FACILITY CLASSIFICATION:

NSPS INSTALLATION CATEGORY – Applicable: The Dry Cleaning Spot utilizes dry cleaning equipment
installed in 2008 with a 110 pound drying capacity. Since the solvent-recovery system was installed after December
14, 1982, and the total manufacturers' rated dryer capacity is greater than or equal to 84 pounds, the facility is subject
to the National New Source Performance Standard (NSPS) for Petroleum Dry Cleaners Subpart JJJ found in Title 40
CFR Part 60, Subpart JJJ (40 CFR Sections 60.620 through 60.625).

Dry Cleaning Equipment Summary

No Type of
Machine
Manufacturer
(Mfr)
Model # Serial # Install Date Solvent Used Observed
Operating?
1 Reclaimer Marvel Petrol
Dry
PC-55 PC550040 2008 Ecosolve yes
2 Reclaimer Marvel Petrol
Dry
PC-55 PC550039 2008 Ecosolve yes
3 Washer Marvel Petrol
Dry
PS-65 PS650017 2008 Ecosolve no

HAZARDOUS WASTE GENERATOR CATEGORY - NA: The Dry Cleaning Spot is not classified as a Hazardous
Waste Generator because the solvent used to clean garments is a blended petroleum solvent (Ecosolve) with a flash
point of 142° F. The Dry Clean Spot has contracted with MCF Systems of Atlanta (MCF) to remove any solvent
waste generated from draining solvent filters and spotting table waste.

(IV) INSPECTION SUMMARY: On October 18, 2012, Jack Kitchen, Compliance Inspector, with the North Carolina
Division of Waste Management, Dry Cleaning Solvent Cleanup Act (DSCA) Program conducted a Compliance Inspection
at the Dry Cleaning Spot. The inspector met with Ms. Patricia Hilliard, store employee, who provided the inspector
access to the facility's equipment and available records. Ms. Hilliard called the owner, Mr. Nick Patel, to make him aware
of the inspection. Mr. Patel was unable to be present for the inspection.

On the day of the inspection, the reclaimer dryers were in operation without any observable leaks. The Marvel transfer
washer and reclaimer dryers were installed within one large metal spill containment pan. Ms. Hilliard stated that they dry
clean about five loads per day.

The inspector contacted the Phenix Supply Company and verified that four 55-gallon drums of solvent were purchased in
the past 12 months. A 55-gallon drum of Ecosolve dry cleaning solvent was stored on a spill containment deck equipped
with an expandable bladder. The spill containment has a volumetric capacity of 66 gallons, which is compliant with the
North Carolina Minimum Management Practice (MMP) that requires all solvent and solvent waste must be stored in spill
containment that has a volumetric capacity of 110% of the largest vessel being stored in that spill containment.

A 55-gallon solvent waste drum is stored in adequately sized spill containment near the rear door of the facility. The
inspector contacted MCF Systems of Atlanta (MCF) and their records indicate that a 55-gallon drum was provided in
2009 and they have not picked-up any waste from the facility since the Dry Clean Spot became a customer.

Solvent is filtered in a Kleenrite filtering system consisting of three filter columns. Each column contains six carbon
cartridge filters. Solvent is filtered through one column until the filters no longer remove impurities and dies, (spent).
When a column of filters is spent, solvent is directed to a different column in the system. Spent solvent filters are drained
in the housing for at least eight hours before they are removed and placed in plastic bags to allow for further draining.
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After additional draining, the dry filters are placed in the municipal waste (dumpster) to be placed in a land fill. The small
amount of solvent collected in the plastic bags is placed into the waste drum. Ms. Hilliard estimated less than ½ gallon of
waste solvent is generated from the additional draining of four filters. The dates that solvent filters are changed are kept in
a log. In the past 12 months, eleven columns of filters have been replaced. It is estimated that five gallons of liquid solvent
waste is generated yearly. Spotting table waste is collected and is periodically added to the solvent waste drum.

The facility treats and disposes of separator water with an onsite wastewater treatment unit (WWTU). The WWTU is a
Galaxy Mister that utilizes dual carbon filtration to remove miscible solvent from the separator water and compressed air
misting is used to assist with the evaporation of the filtered water. The filtration unit is stored in the spill containment pan
that is installed under and around the dry cleaning washer and the two reclaimer dryers. The misting nozzle is mounted
on the roof and is not visible from the ground. The inspector recommended that the nozzle be relocated for regular visible
inspections. The facility keeps a log of WWTU filter changes and keeps replacement filters on site. The WWTU filters
were changed on December 13, 2011, April 10, 2012, and July 15, 2012. Ms. Hilliard stated that the used WWTU filters
are placed in the solvent waste drum. Clothes press vacuum pump condensate is also collected and treated in the WWTU.

The facility is subject to the New Source Performance Standards outlined in Subpart JJJ in the 40 CFR Part 60. The dry
cleaning operation utilizes cartridge solvent, which are drained in their housing for at least 8 hours prior to changing them.
The facility utilizes a transfer washer and two solvent reclaiming dyers, which are required by Subpart JJJ. The dry
cleaning equipment is clearly labeled by the manufacturer with leak inspection procedures. The reclaimed solvent from
the two Marvel PC-55 reclaimer dryers is directly plumbed to the solvent tank of the Marvel PS-65 washer. The quantity
of reclaimed solvent cannot be quantified without modifying the plumbing. Based on solvent purchases of 220 gallons in
the past 12 months and Ms. Hilliard’s estimation that 25 loads of dry cleaning are performed weekly, it is likely that no
more than 21 ounces of solvent is unrecovered per load.

(V) CONCLUSIONS: Based on observations documented by the DSCA Inspector during the October 18, 2012
inspection, the Dry Cleaning Spot was in compliance with the DSCA Required Minimum Management Practices provided
in 15A NCAC 02S.0202, National New Source Performance Standard (NSPS) for Petroleum Dry Cleaners Subpart JJJ
found in Title 40 CFR Part 60, Subpart JJJ (40 CFR Sections 60.620 through 60.625), and Recovery Act (RCRA)
referenced in 40 CFR part 261.5 and 262.

(VI) ENFORCEMENT HISTORY (Penalties): None

(VII) RECOMMENDATIONS: At the time of the inspection, no violations were observed. A targeted inspection
should be conducted by October 18, 2013 to confirm ongoing compliance.