20150724MorrisvilleDryClnrs_RPT

NORTH CAROLINA DIVISION OF WASTE MANAGEMENT
Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program
Inspection Report
Date: 7/27/2015

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: 7/24/2015
Time In: 08:45 AM Time Out: 10:15 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: 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 Ltd
Partnership
Duke Realty Corp
PO Box 40509
Indianapolis, IN 46240

Inspector’s Signature:

Date of Signature: 7/30/2015

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. 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 pickup
locations.

Solvent History:
Solvent Dates Used
DF2000 10/29/2009 to Present

Previous Inspections:
Date Visit Type Violation
Type(s)
Worst Violation(s) Action(s)
Taken
Response
Due
Received
Date
Inspector
7/31/2014 Initial
Inspection
MMP Inadequate spill
containment
CHKLST
sent on
7/31/2014
8/21/2014 8/21/2014 Pam
Moore
9/13/2012 Outreach
Training
Visit
MMP No spill containment
(solvent and waste
storage areas)
CAL sent
on
9/25/2012
10/16/2012 Not Rec'd 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.
The solvent used (DF2000) is classified as non-hazardous and non-ignitable; the flash point of the solvent is greater
than 140°F. 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 EWS Alabama Inc. in Glencoe, AL (EPA ID# ALD981020894).
Three years of waste manifests were on site and available for review. Approximately 23 pounds of solvent waste are
generated per month. In the past 12 months, no facility-generated waste was transported off site. The last waste
pickup occurred on February 5, 2014, when a total of 550 pounds of solvent waste were transported off site (Liquid
waste). One partially full 55-gallon drum of solvent waste was observed on site at the time of the inspection (approx.
275 lbs.). The facility does not utilize an onsite wastewater treatment unit (WWTU) to dispose of facility-generated
contact water.

(IV) INSPECTION SUMMARY: On July 24, 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 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 previous inspections, as listed above. The
machine is normally operated from 8 a.m. to 1 p.m. Monday through Friday and was observed in operation. No leaks or
other problems were observed with the machine. Separator water is collected in a 5-gallon container (picture 2) behind
the dry cleaning machine that is not in spill containment. The inspector reminded Mr. Desai that the container must be in
spill containment of at least 5.5 gallon capacity or larger. Approximately 3.5 gallons was observed in the container, but
Joe Nucharel, the machine operator, told the inspector that most of what was in the container is solvent, with only a small
amount of water at the bottom of the container; the inspector could clearly see the separation of the reclaimed solvent and
the water in the container. Joe stated the reclaimed solvent is poured back into the dry cleaning machine and the water is
disposed in the waste drum. Joe estimated that about one gallon of separator water is generated every two weeks. Solvent
filters are changed every six to eight weeks and are drained over the weekend prior to removal and disposal. Mr. Desai
said the still is cleaned out once per week, on Saturday, and the small amount of still waste is disposed in the waste drum.

The 55-gallon waste drum (labeled “Non-Regulated”) is located behind the dry cleaning machine in spill containment but
the capacity of the spill containment unit is less than 110% of the capacity of the waste drum (picture 1). This situation
was observed during the previous inspection; however, the installation and use of the current spill containment unit was a
result of miscommunication between Mr. Desai and the DSCA inspector in 2012 (see 7/31/14 inspection report). During
the 2014 inspection, Mr. Desai understood that the spill containment unit was too small and told the inspector once the 55-
gallon waste drum was full and picked up by MCF that he would have MCF supply him with 15-gallon waste drums (Mr.
Desai said MCF would charge him the same price if the 55-gallon drum was full or only contained a few gallons of waste,
and he could not afford to have them pick up the drum until it was full). The inspector observed that the 55-gallon waste
drum onsite was the same waste drum observed during the July 2014 inspection and the drum was not yet full. Mr. Desai
again told the inspector that he would have MCF supply the smaller waste drums after the 55-gallon drum was full and
had been picked up.

The facility had a 55-gallon drum of DF2000 solvent (picture 1) stored on site, behind the dry cleaning machine in the
same spill containment unit as the waste drum. The capacity of the spill containment unit is too small for the 55-gallon
solvent drum. Mr. Desai said he usually does not store solvent onsite and that only a few gallons of solvent were in the
drum and that he would place the remaining solvent into the machine shortly. Mr. Desai said he would start buying
solvent in the 5-gallon containers in the future.

The vacuum pump is located next to the waste storage drum. Pump condensate is drained directly into the waste drum via
a hose attached to the drain valve. Mr. Desai and Mr. Nucharel said not a lot of condensate is generated but since it drains
directly into the drum the exact amount generated is not known. The spotting table is located in front of the dry cleaning
machine and is equipped with a waste collection container.

An emergency information form was completed and posted, and spill cleanup material was stored on site.

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

2. 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 24, 2015 inspection,
Morrisville Dry Cleaners is currently in violation of the following regulations:

MMPs - 15A NCAC 02S.0202
(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.
(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 (#01826) 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 14, 2015, the actions taken to bring about compliance. A follow-up inspection
should be conducted by July 24, 2016 to confirm compliance.

Picture 1: Waste solvent drum (black, right) and DF2000 solvent drum (red, left) in spill containment that is less than
110% capacity of the drums.

Picture 2: Separator water container not in spill containment; most of liquid in container is reclaimed solvent, water is at
the bottom (arrow).