20180525DryCleanSpot_RPT

NORTH CAROLINA DIVISION OF WASTE MANAGEMENT
Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program
Inspection Report
Date: 5/29/2018

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: 5/25/2018
Time In: 8:50 AM Time Out: 9:40 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
Nick Patel
1142 N Main St
Fuquay Varina, NC
27526-2613
[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: 6/1/2018

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 a real estate office on the right and an empty 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
3/23/2017 Follow up
Inspection
In
Compliance
N/A CHKLST
sent on
3/23/2017
None N/A Pam
Moore
9/22/2016 Inspection MMP No WWTU records CHKLST
sent on
9/22/2016

NOV sent
9/29/2016
None

1/18/2017
N/A

1/30/2017
Pam
Moore
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 on
10/18/2012
None N/A Jack
Kitchen
12/6/2011 Initial
Inspection
MMP Spill containment CHKLST
sent on
12/6/2011

NOV sent
2/14/2012
12/27/2011

3/6/2012
12/29/2011

3/6/2012
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 solvent used is classified as non-hazardous and non-ignitable. The solvent used has a flash point
greater than 140°F. The facility has contracted with MCF Systems of Atlanta for solvent waste disposal.

(IV) INSPECTION SUMMARY: On May 25, 2018, 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 Mr. Serrano Al Fredo, store employee, who provided the inspector access to the facility's
equipment and available records.

The facility continues to use the same petroleum dry cleaning equipment observed during previous inspections, consisting
of a washer and two solvent recovery dryers. A separate filter tower is adjacent to the washer. The dry cleaning equipment
is normally operated from 7:00 a.m. to 10:00 a.m. Monday through Friday and was observed in operation. No leaks or other
problems were observed with the equipment. Separator water from each dryer is collected in a container within spill
containment and treated onsite. About 6 gallons of separator water are generated per week. Solvent filters in one of the
housings are changed each month and are drained a minimum of 8 hours prior to removal and disposal.

A 55-gallon drum of Ecosolv solvent is stored onsite in front of the washer, in spill containment (deck with expandable
bladder attachment).

A 55-gallon solvent waste drum is stored out back of the facility in an uncovered locked gated area, but the drum is not in
spill containment (pictures 1-2). During the March 2017 the facility had moved the solvent waste drum from inside the
facility to the gated area to make room for the installation of a new shirt press; at that time the waste drum was empty but
there was a spill deck just inside the back door of the facility where it is usually stored. The inspector was told in 2017 that
the drum would be moved back inside and placed onto the spill deck prior to any waste being placed in it. The drum was
never moved back inside and now is partially full of solvent waste, not in spill containment and subject to rain. The drum
is within a locked area but is accessible to the public. The inspector told Mr. Al Fredo to have the drum moved back inside
immediately; Mr. Al Fredo said he was waiting on the owner to get someone with a large dolly to move the drum back
inside.

The vacuum pump is in the boiler room. Pump condensate is drained into a container and treated onsite. Depending on the
time of year, about 4 to 6 gallons of condensate are generated per week.

Facility generated contact water is treated onsite in a Galaxy mister, located in the spill pan of one of the solvent recovery
dryers. The misting nozzle is mounted on the roof of the building and is not visible from outside the building. Mr. Al Fredo
said the filters on the mister are changed once per year but there was no documentation of the last filter change. Mr. Al
Fredo said he thought the last filter change was in May or June of 2017. Mr. Al Fredo did not know where the DSCA
Petroleum calendar was located so the inspector could not review the WWTU inspection and filter change log. Based on
the estimated amount of contact water generated, the facility should be changing the filters on the mister about every 10
months and informed Mr. Al Fredo. Mr. Al Fredo showed the inspector a set of replacement filters and said he would have
the filters changed as soon as possible; the inspector reminded him to record the date of the filter change.

When the inspector asked Mr. Al Fredo for the waste manifests, he said he did not know where they were located so the
inspector could not review them. The operation manual for the WWTU was onsite, an emergency information form was
completed and posted and spill cleanup material was stored onsite.

Picrin is used as a spotting agent but it is not clear how much is used. A mostly full 1-gallon container was observed onsite
(picture 3) and a small squeeze bottle was on the spotting table, but Mr. Al Fredo did not know how much Picrin is purchased
in a year. Other spotting agents used are Pyratex, APOG, StreeTan, StreePro and Spotless.

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 dry-cleaning solvent waste disposal invoices was not made available to the
Department.

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

3. Spill containment was not installed under and around the waste solvent storage containers.

NSPS VIOLATIONS - 40 CFR Part 60, Subpart JJJ
None

(V) CONCLUSIONS: Based on observations documented by the DSCA Inspector during the May 25, 2018 inspection,
Dry Clean Spot is currently in violation of the following regulations:

MMPs - 15A NCAC 02S.0202
(b)(1) Failure to maintain complete and current invoices for waste disposal [15A NCAC 02S.0202(b)(1)].
Waste manifests are required to be kept on site for three years and available for review.
(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.
(b)(2) Failure to maintain spill containment under and around the waste solvent storage area by January 1,
2002 [15 NCAC 0202 (b)(2)]. Spill containment shall have a volumetric capacity of 110 percent of
the largest vessel, tank, or container within the spill containment area and shall be capable of
preventing the release of the applicable dry cleaning solvent beyond the spill containment area for a
period of at least 72 hours.

(VI) ENFORCEMENT HISTORY (Penalties): None

(VII) RECOMMENDATIONS: A DSCA Compliance Program Checklist (#02753) was issued to Mr. Serrano Al Fredo,
employee of Dry Clean Spot, indicating the compliance issues to be addressed. Mr. Al Fredo was instructed to respond to
DSCA Compliance in writing by June 15, 2018, the actions taken to bring about compliance. A follow-up inspection should
be conducted by May 25, 2019 to confirm compliance.

(VIII) PHOTOGRAPHS:

Picture 1: A 55-gallon solvent waste drum without spill containment stored outside in an uncovered locked gated area.

Picture 2: The uncovered locked gated area where the waste drum is stored.

Picture 3: A mostly full 1-gallon container of Picrin spotting agent.