20140731MorrisvilleDryClnrs_RPT

NORTH CAROLINA DIVISION OF WASTE MANAGEMENT
Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program
Initial Inspection Report
Date: 7/31/2014

Facility Identification
Morrisville Dry Cleaners
Facility ID: 920074C
EPA Generator ID: NCCESQG
County/FIPS: Wake/183
DSCA Cleanup ID:
Facility Data
Morrisville Dry Cleaners
10970 Chapel Hill Road, Ste. 126
Morrisville NC 27560
Lat: 35.85598 Long: -78.84031
SIC: 7216 / Dry Cleaning Plants, Except Rugs
NAICS: 81232/ Dry Cleaning and Laundry Services (except Coin-Operated)
Date of Facility Establishment: 10/29/2009
Compliance Data
Inspection Date: 7/31/2014
Time In: 08:30 AM Time Out: 09:25 AM
Inspector: Pam Moore
Operating Status: OO/Operating
Compliance Codes: In Violation of MMP
Action Code: 10/Initial Inspection
Contact Data Classification Data
Service Type: Full Service (Active)
Solvent: DF2000
System: Dry-to-Dry
Installation Date: 2009
Installation Category: N/A
Consumption Category: N/A
HW Generator Status: CESQG
Facility Contact
Kishan Desai
10970 Chapel Hill Road,
Ste. 126
Morrisville, NC 27560
[phone]
Facility Owner
Kishan Desai
10970 Chapel Hill Road,
Ste. 126
Morrisville, NC 27560
[phone]
Property Owner
Duke Construction LP
Duke Realty Corp
PO Box 40509
Indianapolis, IN 46240-
0509

Inspector’s Signature:

Date of Signature: 7/31/2014

Comments:

(I) DIRECTIONS: From the DENR Green Square building located at 217 W Jones St (Raleigh), go east on W Jones St
toward N McDowell St. Take the 1st left onto N McDowell St and continue onto Capital Blvd. Take the Wade Avenue
ramp and merge onto US-70 W/Wade Ave. Continue to follow Wade Ave and merge onto I-40 West. Proceed for
approximately 12 miles. Take exit 284 for Airport Blvd and turn left onto Airport Blvd. Turn right onto NC 54 W/Chapel
Hill Rd. The facility will be on the right, in Perimeter Park.

(II) FACILITY HISTORY: Morrisville Dry Cleaners is a petroleum solvent dry cleaning plant that has been owned and
operated by Mr. Kishan Desai since its establishment in October 2009. The facility is open from 7 am to 7 pm M-F and 8
am to 2 pm on Saturday. The facility is attached to the Daily Grind coffee shop and does not service any area pickup
locations.

Solvent History:

Solvent Dates Used
DF2000 10/29/2009 to Present

Previous Inspections:

Date Visit Type Violation
Types
Worst
Violation(s)
Action Taken Response
Due
Received
Date
Inspector
9/13/2012 Outreach
Training Visit
MMP No spill
containment
(solvent and waste
storage areas)
CAL sent on
9/25/2012
10/16/2012 11/12/2012 Alicia Roh

Complaints: None

DSCA Sampling: None

(III) FACILITY CLASSIFICATION:

NSPS INSTALLATION CATEGORY – Not Applicable: Morrisville Dry Cleaners utilizes dry cleaning equipment
installed in 2009 with a 60 pound drying capacity. Although the solvent-recovery system was installed after
December 14, 1982, the total manufacturers' rated dryer capacity was less than 84 pounds. Therefore the facility is
not 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 Dry-to-
Dry
n/a Union HL 860 607 B9 1048 2009 10/1/2009 N/A DF2000 yes

HAZARDOUS WASTE GENERATOR CATEGORY - CESQG: Morrisville Dry Cleaners is classified as a
Conditionally Exempt Small Quantity Generator (CESQG) because the facility has routinely generated less than 220
pounds of waste per month during the past 12 months, and stores less than 2,200 pounds of solvent waste on site.
Morrisville Dry Cleaners has contracted with MCF Systems of Atlanta (EPA ID# GAD981269095) to transport the
facility-generated solvent waste to a licensed Treatment Storage or Disposal (TSD) facility. The most recent solvent
waste generated was transported to Safety Kleen in Cranston RI (EPA ID# RID084802842). Three years of waste
manifests WERE on site and available for review. Approximately 63 pounds of solvent (non-hazardous) waste are
generated per month. In the past 12 months, 550 pounds of facility-generated waste were transported off site. The last
waste pickup occurred on August 6, 2013, when a total of 550 pounds of hazardous waste were transported off site
(Liquid & Filters waste). One partially full 55-gallon drum of solvent waste was observed on site at the time of the
inspection (approx. 200 lbs).

(IV) INSPECTION SUMMARY: On July 31, 2014, Pam Moore, Compliance Inspector, with the North Carolina
Division of Waste Management, Dry Cleaning Solvent Cleanup Act (DSCA) Program conducted a Compliance Inspection
at Morrisville Dry Cleaners. The inspector met with Mr. Kishan Desai, store owner, who provided the inspector access to
the facility's equipment and available records.

The facility continues to use the same dry cleaning machine observed during the previous inspection, as listed above. The
machine is normally operated from 8 a.m. to noon Monday through Friday and was observed in operation. No leaks or
problems were observed with the machine. Separator water is collected in a plastic container located in spill containment,
and is disposed in the 55-gallon solvent waste drum. Solvent filters are changed about once per year and are drained over
the weekend prior to removal and disposal. Mr. Desai stated he has been disposing of the spent filters in the waste drum
but may begin disposing of them in the regular trash after making sure they are completely dry. The solvent used is
DF2000 and no solvent was observed stored onsite. Mr. Desai stated that when he buys a 55-gallon drum of DF2000 if all
of it isn’t immediately placed into the machine, he stores the solvent drum on the spill containment unit he purchased after
the outreach visit in 2012. Mr. Desai said business is slow and he buys a drum of solvent only about every 12-18 months.

The solvent waste storage area is behind the dry cleaning machine in spill containment. During the 2012 outreach visit it
was noted that the solvent waste drum and the solvent drum were stored onsite without spill containment. The inspector
told Mr. Desai during the outreach visit that the drums must be in adequate spill containment and explained about the
110% volumetric capacity regulation and provided him with a copy of the MMPs. Ms. Moore observed that the spill
containment unit Mr. Desai obtained and has been using is not of sufficient capacity for the 55-gallon drum. The spill
deck has sufficient surface area to accommodate two 55-gallon drums but the containment unit is not deep enough to
contain the required 60.5 gallons (110%). Mr. Desai said he purchased the spill containment unit the inspector told him to
in 2012 and he paid quite a bit for it and could not afford to replace it. Ms. Moore suggested that Mr. Desai could begin
using smaller waste drums and purchase solvent in 5-gallon containers. The 55-gallon waste drum currently being used is
only half full and Mr. Desai does not want to have it picked up yet since MCF would charge him the same as a full drum.

The vacuum pump is located next to the waste storage area. Pump condensate is drained directly from the pump into the
waste drum via a hose. Mr. Desai said the vacuum pump does not generate much condensate because it is only connected
to one piece of pressing equipment.

Manifests for waste pickups were on site (not well organized). An emergency information form was completed and
posted and spill cleanup material (dedicated towels and blankets) was stored on site.

NOTE: While preparing for the inspection I reviewed the database and past inspection information in the electronic
folder. This facility has only been visited once before, an outreach visit on Sept. 13, 2012 (facility established Oct. 2009).
During the outreach visit the facility was found to have two violations, the solvent drum and the solvent waste drum were
not in spill containment. A note entered into the database by the inspector, Alicia Roh, stated that a checklist was not left
with the owner, Mr. Desai, because she had the wrong checklist book in her car, and instead a Corrective Action Letter
would be sent. The CAL was sent on 9/25/2012 and the green card was signed for on 9/26/2012. The database indicates
that no response to the CAL was received. When I gave Mr. Desai the checklist after the current inspection, I told him it
was very important to respond to the checklist by the deadline and mentioned that DSCA had not received a response to
the CAL issued to him in 2012. Mr. Desai was very adamant that he had responded in 2012, by sending an email to Alicia
with a photograph of the spill unit he had purchased. Upon returning to the office I contacted Alicia and told her what Mr.
Desai said. Alicia reviewed her records and determined that Mr. Desai had indeed sent her an email on Nov. 12, 2012 and
attached a photograph of the spill unit, but this information was never placed into the electronic folder. The photograph
shows that the spill unit is not of sufficient capacity for the 55-gallon drum. I will call Mr. Desai and remind him to be
sure to respond to the checklist (he told me he will say that after the 55-gallon waste drum is full he will have it picked up
and have MCF leave the smaller 15-gallon waste drum at the facility), and instruct him to contact me after the 55-gallon
drum has been picked up so that I can verify the facility then is using the 15-gallon waste drum.

The following is a summary of Morrisville Dry Cleaners' 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. The spill containment being utilized has a volumetric capacity less than 110 percent of the largest container that
it is storing.

RCRA VIOLATIONS - Hazardous Waste Regulations: 40 CFR Part 262.34
None

(V) CONCLUSIONS: Based on observations documented by the DSCA Inspector during the July 31, 2014 inspection,
Morrisville Dry Cleaners is currently in violation of the following regulations:

MMPs - 15A NCAC 02S.0202
(b)(2) Failure to install spill containment with a volumetric capacity of 110 percent of the largest vessel,
tank, or container within the spill containment area and capable of preventing the release of the
applicable dry cleaning solvent beyond the spill containment area for a period of at least 72 hours.
[15 NCAC 0202 (b)(2)].

(VI) ENFORCEMENT HISTORY (Penalties): None

(VII) RECOMMENDATIONS: A DSCA Compliance Program Checklist (#01211) was issued to Mr. Kishan Desai,
owner of Morrisville Dry Cleaners, indicating the compliance issues to be addressed. Mr. Desai was instructed to respond
to DSCA Compliance in writing by August 21, 2014, the actions taken to bring about compliance. A follow-up inspection
should be conducted by July 31, 2015 to confirm compliance.

Spill containment unit purchased by owner after the 2012 outreach visit. The unit is not of sufficient capacity for the 55-
gallon waste drum. The plastic container on the left is the separator water collection container.