20151117DryCleanSpot_RPT

NORTH CAROLINA DIVISION OF WASTE MANAGEMENT
Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program
Inspection Report
Date: 11/17/2015

Facility Identification
Dry Clean Spot
Facility ID: 920071C
EPA Generator ID: NCCESQG
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: 11/17/2015
Time In: 09:50 AM Time Out: 11:20 AM
Inspector: Pam Moore
Operating Status: OO/Operating
Compliance Codes: In Violation of MMP
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: NA
Facility Contact
Patricia Hilliard
1142 N. Main St.
Fuquay-Varina, NC
27526
[phone]
[phone]
Facility Owner
Nick Patel
1142 N. Main St.
Fuquay-Varina, NC
27526
[phone]
[phone]
Property Owner
Blalock Properties
6741 Rock Service
Station Rd
Raleigh, NC 27603

Inspector’s Signature:

Date of Signature: 11/23/2015

Comments:

(I) DIRECTIONS: From the DSCA office at Green Square located in Raleigh, travel south on Dawson St/Capital Blvd.
Keep to the right to stay on US-401 S. Stay 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 plant. 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 attached to an empty store on the right and a gift store on the left. The facility does not service any pickup
stores.

Solvent History:
Solvent Dates Used
Ecosolve Start date unknown to Present

Previous Inspections:
Date Visit Type Violation
Type(s)
Worst Violation(s) Action(s)
Taken
Response
Due
Received
Date
Inspector
7/22/2014 Inspection In
Compliance
N/A CHKLST
sent on
7/22/2014
None N/A Pam
Moore
10/18/2012 Inspection In
Compliance
N/A CHKLST
sent on
10/18/2012
None N/A Jack
Kitchen
12/6/2011 Initial
Inspection
MMP Spill containment NOV sent
on
2/14/2012

CHKLST
sent on
12/6/2011
3/6/2012

12/27/2011
3/6/2012

12/29/2011
Pam
Moore
8/11/2009 Outreach
Training
Visit
MMP Spill containment
Recordkeeping
CAL sent
on
8/19/2009
9/8/2009 Not Rec'd Sarah
Gornick

Complaints: None

DSCA Sampling: None

(III) FACILITY CLASSIFICATION:

NSPS INSTALLATION CATEGORY – Applicable: Dry Clean 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
Gen Manufacturer
(Mfr)
Model # Serial # Mfr
Date
Install
Date
End
Date
Solvent Used Observed
Operating?
1 Reclaimer n/a Marvel Petrol
Dry
PC-55 PC550040 -- 2008 N/A Ecosolve yes
2 Reclaimer n/a Marvel Petrol
Dry
PC-55 PC550039 -- 2008 N/A Ecosolve yes
3 Washer n/a Marvel Petrol
Dry
PS-65 PS650017 -- 2008 N/A Ecosolve yes
4 --Other-- n/a Kleenrite
Solvent Filters
FC-3H -- -- 2008 N/A Ecosolve --

HAZARDOUS WASTE GENERATOR CATEGORY - NA: Dry Clean Spot is not classified as a Hazardous Waste
Generator because the petroleum based solvent used (Ecosolv) is not classified as a hazardous substance and it is not
ignitable because the flash point is 142°F.

(IV) INSPECTION SUMMARY: On November 17, 2015, 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. The inspector met with Ms. Patricia Hilliard, store manager, who provided the inspector access to the
facility's equipment and available records.

The facility continues to use the same dry cleaning equipment observed during previous inspections, a petroleum transfer
system with a washer and two solvent recovery dryers. The equipment is normally operated from 5 a.m. to 11 a.m.
Monday through Friday and was observed in operation. No leaks or other problems were observed. Separator water is
collected from the reclaimers in containers located within spill containment. A total of about 8 gallons of separator water
is generated per week and treated onsite. A separate filter tower is located behind the washer in spill containment. There
are three housings and filters in one of the housings are changed each month and are drained more than 8 hours prior to
removal and disposal in the regular trash. The dry cleaning system does not have a still and therefore no solvent still
waste is generated.

One 55-gallon drum of Ecosolv solvent is stored onsite, adjacent to the dry cleaning washer in spill containment. The
spill containment unit is equipped with an expandable bladder attachment which provides the necessary volumetric
capacity.

The facility has a 55-gallon waste drum onsite, near the back door in spill containment (with expandable bladder). The
only waste disposed in the drum are spent filters from the wastewater treatment unit. The drum was about half full.

Facility generated contact water is treated in a Galaxy mister located within the spill pan of the reclaimers. The misting
nozzle is mounted on the roof and is not visible. Ms. Hilliard told the inspector that Mr. Patel changes the filters on the
mister and that she thought he did so every two to three months but was not sure. During the previous inspection it was
noted that the filter change dates were being recorded on a piece of paper attached to the wall near the dry cleaning
machine (the solvent filter change dates are also recorded on the same paper). The inspector looked at the paper attached
to the wall and observed the last WWTU filter change recorded in June 2014. Solvent filter change dates had been
recorded through October 2015. Based on the estimated amount of contact water generated (about 64 gallons per month,
32 gallons from the reclaimers and 32 gallons from the vacuum pump), the filters should be changed every 5 months,
indicating the filters should have been changed three times since the last recorded change date.

The vacuum pump is located in the boiler room. Pump condensate is drained into a container and treated in the mister.
About 8 gallons of condensate are generated per week, according to Ms. Hilliard. The spotting table is located next to the
reclaimers and is equipped with a waste collection container. The inspector observed a 1-gallon container of Picrin on the
floor under the spotting table but it had only a very little in it. Ms. Hilliard said, to her knowledge, it is rarely, if ever,
used.

Waste manifests were onsite, attached to a cork board near the front of the facility. The latest manifest was dated April 9,
2013 and the inspector called MCF and verified that was the last waste pickup. Since the facility only uses the 55-gallon
waste drum to dispose spent filters from the WWTU it takes a long time to fill it up. The inspector saw that the invoice
for the waste manifest was attached and noticed it read, “PERC still bottom liquid”, and then noticed that the manifest
listed the waste as “tetrachloroethylene”. The inspector pointed this out to Ms. Hilliard and recommended that she have
Mr. Patel contact MCF to be sure they were correctly identifying the waste.

An emergency information form was completed and posted by the phone, the operation manual for the mister was onsite,
and spill cleanup material (pig mats) was stored onsite. The inspector gave Ms. Hilliard a copy of the 2015 petroleum
compliance calendar and instructed her on how to complete the WWTU inspection log and where to record the filter
change dates for the mister.

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, 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.

MMP VIOLATIONS - 15A NCAC 02S.0202

1. A complete three year history of records of purchase, maintenance, and service of wastewater treatment
equipment was not made available to the Department.

NSPS VIOLATIONS - 40 CFR Part 60, Subpart JJJ
None

(V) CONCLUSIONS: Based on observations documented by the DSCA Inspector during the November 17, 2015
inspection, Dry Clean Spot is currently in violation of the following regulations:

MMPs - 15A NCAC 02S.0202
(b)(1) Failure to maintain and/or make available to the Department required records pertaining to the
wastewater treatment unit (atomizer, evaporator, carbon filter, or other equipment for the treatment
of wastewater containing solvents) [15A NCAC 02S.0202(b)(1)]. Records shall be kept for a period
of three years.

(VI) ENFORCEMENT HISTORY (Penalties): None

(VII) RECOMMENDATIONS: A DSCA Compliance Program Checklist (#01645) was issued to Ms. Patricia Hilliard,
manager of Dry Clean Spot, indicating the compliance issues to be addressed. Ms. Hilliard was instructed to respond (or
have Mr. Nick Patel respond) to DSCA Compliance in writing by December 8, 2015, the actions taken to bring about
compliance. A follow-up inspection should be conducted by November 17, 2016 to confirm compliance.

Petroleum washer (right) and one of the two reclaimers (left).

55-gallon waste drum only used for spent WWTU filters, in spill containment.

Invoice from MCF for waste pickup, with “PERC STILL BOTTOM LIQUID” listed as the waste; this facility was
established in 2008 as a petroleum plant and has only ever used a non-hazardous petroleum solvent, Ecosolv.