20160922DryCleanSpot_RPT

NORTH CAROLINA DIVISION OF WASTE MANAGEMENT
Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program
Inspection Report
Date: 9/22/2016

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: 9/22/2016
Time In: 09:15 AM Time Out: 10:05 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: Ecosolv
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: 9/22/2016

Comments: Repeat violation for no WWTU filter change log, inspection log
and filter purchase receipt. NOV to be issued.

(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 conduct dry cleaning for 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
11/17/2015 Inspection MMP No WWTU records
(not all filter change
dates were recorded)
CHKLST
sent on
11/17/2015
12/8/2015 12/8/2015 Pam
Moore
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
10/18/2012
None N/A Jack
Kitchen
12/6/2011 Initial
Inspection
MMP Spill containment NOV sent
on
2/14/2012

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

None
3/6/2012

N/A
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 Ecosolv yes
2 Reclaimer n/a Marvel Petrol
Dry
PC-55 PC550039 -- 2008 N/A Ecosolv yes
3 Washer n/a Marvel Petrol
Dry
PS-65 PS650017 -- 2008 N/A Ecosolv yes
4 --Other-- n/a Kleenrite
Solvent Filters
FC-3H -- -- 2008 N/A Ecosolv --

HAZARDOUS WASTE GENERATOR CATEGORY - NA: Dry Clean Spot is not classified as a Hazardous Waste
Generator because the solvent being used is classified as non-hazardous and non-ignitable. The flash point of the
solvent being used is greater than 140°F. MCF Systems of Atlanta is contracted to remove solvent waste.

(IV) INSPECTION SUMMARY: On September 22, 2016, 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 consisting of a Marvel washer and two Marvel solvent-recovery dryers, all installed in 2008 with spill containment.
A separate filter tower is located behind the washer in spill containment. 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. The filter
tower consists of three housings and the filters in one housing are changed each month; the filters are drained at least 8
hours in the housing prior to removal and disposal in the regular trash. Separator water from each reclaimer is collected in
a container located within the spill pan of the reclaimer. Approximately 8 gallons total of separator water are generated per
week and treated onsite.

A 55-gallon drum of Ecosolv solvent is stored onsite, at the rear of the Marvel washer in spill containment. Because the
washer does not have a still, no solvent waste is generated. However, the facility uses a 55-gallon waste drum to dispose of
spent filters from the wastewater treatment unit. The waste drum is normally stored on a spill deck next to the back door of
the facility. However, the waste drum was recently moved temporarily to a locked gated outside area because a new shirt
press was delivered and the waste drum was in the way of bringing it in at the back door. Ms. Hilliard said the drum will
be moved back to its normal location in a couple of days, after the new shirt press has its final inspection.

The vacuum pump is located in the boiler room. Pump condensate is drained into a container and treated onsite. No
condensate was observed in the collection container and about 7 gallons of condensate are generated per week.

A Galaxy mister is used to treat contact water onsite. The mister is located within the spill pan of the reclaimer. The misting
nozzle continues to be mounted on the roof the building and is not visible. From 2011 through 2014 the facility recorded
filter change dates for the mister on a log sheet attached to the wall behind the dry cleaning equipment next to the entrance
to the boiler room. The log sheet was divided into two columns, one for recording the dates of the solvent filter changes
and the other for recording the mister filter changes. As noted in the report from the previous inspection (conducted
11/17/2015) the last filter change date recorded was in June 2014. No filter change dates have been recorded since the June
2014 recorded date, but solvent filter change dates continue to be recorded monthly. During the November 2015 inspection
a copy of the 2015 petroleum compliance calendar was given to Ms. Hilliard and she was instructed how to complete the
WWTU inspection and filter change log weekly. Because Ms. Hilliard only works at the front counter and does not operate
the WWTU, she said she would give the calendar to Mr. Patel, the owner. The inspector asked if the 2015 petroleum
calendar was onsite, Ms. Hilliard said she gave the calendar to Mr. Patel and that he took it with him. The inspector asked
Ms. Hilliard if she knew when the filters had been changed on the mister and she said she had no idea. The inspector asked
Ms. Hilliard if any filter purchase receipts were onsite, she said she had no idea where they would be. The inspector gave
Ms. Hilliard a copy of the 2016 petroleum compliance calendar and again explained how to complete the WWTU weekly
inspection log and where to record the filter change dates and requested that Ms. Hilliard give the calendar to Mr. Patel,
explain to him how to complete the inspection log and remind him that the calendar must remain onsite for review by the
inspector. Ms. Hilliard said she would do so.

The spotting table is located next to the reclaimers and is equipped with a waste collection container. Spotting agents used
include APOG, RustGo, StreeTan and Picrin. During the November 2015 inspection a 1-gallon container of Picrin was
observed onsite with a small amount of the spotting agent in the container; Ms. Hilliard said at that time that it is almost
never used. The same 1-gallon container was still onsite and contained very little material, but the inspector observed a
small squeeze bottle labeled Picrin on top of the spotting table.

Waste manifests were onsite; the facility has not had a waste pickup since the previous inspection. As stated above, the
only waste generated are the spent filters from the mister and it takes a long time to fill up the 55-gallon waste drum.

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 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 September 22, 2016
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 (#02016) was issued to Ms. Patricia Hilliard,
manager of Dry Clean Spot, indicating the compliance issues to be addressed. A Notice of Violation (NOV) will be issued
to Mr. Nick Patel for the violations observed during the inspection. A follow-up inspection should be conducted by March
22, 2017 to confirm compliance.

PHOTOGRAPHS:

Filter change log sheet on wall behind dry cleaning machine; column on left for solvent filter change dates, column on right
used for WWTU filter change dates. Last WWTU filter change 8/9/2014.

Current filter change log, with only the solvent filter changes noted (for filter housings 1, 2 & 3); no WWTU filter changes
listed on the right side.