20121102$199DryCleanXPress_RPT

NORTH CAROLINA DIVISION OF WASTE MANAGEMENT
Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program
Outreach Training Visit Report
Date: 11/5/2012

Facility Identification
$1.99 Dry Clean X-Press
Facility ID: 920075C
EPA Generator ID: NCCESQG
County/FIPS: Wake/183
DSCA Cleanup ID: --
Facility Data
$1.99 Dry Clean X-Press
3603 Davis Drive, Ste. 103
Morrisville NC 27560
Lat: 35.8213 Long: -78.8487
SIC: 7216 / Dry Cleaning Plants, Except Rugs
NAICS: 81232/ Dry Cleaning and Laundry Services (except Coin-Operated)
Date of Facility Establishment: 11/1/2009
Compliance Data
Inspection Date: 11/2/2012
Time In: 08:30 AM Time Out: 09:30 AM
Inspector(s): Alicia Roh
Operating Status: OO/Operating
Compliance Codes: In Violation of MMP
Action Code: 00/Outreach Training Visit
Contact Data Classification Data
Service Type: Full Service (Active)
Solvent: Ecosolve
System: Dry-to-Dry
Installation Date: 2009
Installation Category: N/A
Consumption Category: N/A
HW Generator Status: CESQG
Facility Contact
Alex Davogustto
3603 Davis Drive,
Ste. 103
Morrisville, NC 27560
[phone]
Facility Owner
Lomesh Patel
3603 Davis Drive,
Ste. 103
Morrisville, NC 27560
[phone]
[phone] (cell)
Property Owner
Davis Drive 3607 LLC
4400 Triland Way
Cary, NC 27518-2777

Inspector’s Signature:

Date of Signature:

Comments:
MMP violation(s) observed

(I) DIRECTIONS: From the DENR Green Square building located at 217 W Jones St (Raleigh), head 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 keep left at the fork; follow signs for Triangle United Way.
Turn left onto Airport Blvd. Turn right onto NC 54 W/Chapel Hill Rd. Take the 1st left onto McCrimmon Pkwy. Turn left
onto N Carolina 1613/Davis Dr. The facility will be on the right, in the shopping center at the intersection with
Morrisville Carpenter Road.

(II) FACILITY HISTORY: $1.99 Dry Clean X-Press is a petroleum solvent dry cleaning plant that has been owned and
operated by Mr. Lomesh Patel since its establishment in November 2009. As of November 2012, the facility was located
between "Triangle Eye Institute" and a vacant retail space. $1.99 Dry Clean X-Press services the following local pickup
location: Ace Cleaners (2430 Southwest Cary Pkwy) Cary. The dry cleaning equipment is operated Monday-Friday for
an average of 6 loads per day, starting at 8:00 am. Occasionally the machines will be operated on Saturday mornings.

Solvent History:

Solvent Dates Used
Ecosolve 11/1/2009 to Present

Previous Inspections: None

Complaints: None

DSCA Sampling: None

(III) FACILITY CLASSIFICATION:

NSPS INSTALLATION CATEGORY – Applicable: $1.99 Dry Clean X-Press utilizes dry cleaning equipment
installed in 2009 with a 120 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 Dry-to-
Dry
n/a Union HL 860 666-B9-0433 2009 11/1/2009 N/A Ecosolve yes
2 Dry-to-
Dry
n/a Union HL 860 666-H9-0441 2009 11/1/2009 N/A Ecosolve yes

HAZARDOUS WASTE GENERATOR CATEGORY - CESQG: $1.99 Dry Clean X-Press 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 hazardous waste on site.
$1.99 Dry Clean X-Press has contracted with MCF Systems of Atlanta (EPA ID# GAD981269095) to transport the
facility-generated waste to a licensed Treatment Storage or Disposal (TSD) facility. The most recent waste generated
was transported to Clean Harbors Recycling Services of Ohio, LLC in Hebron OH (EPA ID# OHD980587364).
Waste manifests were on site and available for review. Approximately 75 pounds of waste are generated per month.
In the past 12 months, 1,100 pounds of facility-generated waste were transported off site. The last waste pickup
occurred on June 05, 2012, when a total of 550 pounds of waste were transported off site (liquid waste). One half-full
55-gallon drum of non-regulated waste was observed on site at the time of the inspection (approx. 250 lbs). The
facility utilizes an onsite wastewater treatment unit (WWTU) to dispose of facility-generated contact water.

(IV) INSPECTION SUMMARY: On November 2, 2012, Alicia Roh, Compliance Inspector, with the North Carolina
Division of Waste Management, Dry Cleaning Solvent Cleanup Act (DSCA) Program conducted an Outreach Visit at
$1.99 Dry Clean X-Press. The inspector met with Mr. Lomesh Patel, store owner, who provided the inspector access to
the facility's equipment and available records.

Two identical dry-to-dry Union dry cleaning machines were installed within spill containment. Separator water from the
dry cleaning machines was manually drained and collected daily. Mr. Patel stated that the contact water was either
disposed of in the waste drum or treated on site. Water that was ‘too dirty’ was placed in the drum instead of onsite
treatment.

Dry cleaning machine filters were used on an alternating schedule; the 3 filters on the right would be in use, while the 3
filters on the left would drain for over a month. Mr. Patel explained that when he removed the filters, he would allow them
to fully dry in a bucket prior to disposal in the dumpster.

It was brought to Mr. Patel’s attention that vacuum pump condensate and contact water produced by mopping near the dry
cleaning machine were to be treated as contact water. Mr. Patel stated that the vacuum press condensate was manually
drained as needed with the condensate treated on site (or drummed as waste).

A Galaxy wastewater treatment unit (mister), utilizing carbon filtration, was used at the facility. The Galaxy unit was not
stored within spill containment. The nozzles for the Galaxy WWTU were mounted on the exterior of the facility. The
WWTU was not observed in operation during the site visit. Mr. Patel did not have a record of filter changes or routine
maintenance for the WWTU. Mr. Patel was advised to install spill containment underneath the WWTU, obtain the
operation manual, follow the recommended schedule for filter changes outlined per the manufacturer, begin keeping a
maintenance log, and to retain the receipts on site for replacement filters.

Spotting table waste was collected and stored in a second container which served as containment. Mr. Patel emptied the
spotting table waste container during the site visit. Picrin was observed as a spotting agent utilized on site.

The onsite solvent storage area was located behind the dry cleaning machine. One empty 55-gallon drum of EcoSolv was
observed in spill containment. However, inadequate floor space was observed around the spill containment deck (11-
gallons) to allow the 55-gallon spill bladder to properly deploy in the event of a spill or release.

The designated waste storage area was located near the lavatory. The 55-gallon drum containing wastewater was stored in
spill containment. The drum was labeled as “Non-Regulated Waste” by MCF but was not adequately sealed. Mr. Patel
rotated the containment deck to allow adequate floor space for the spill bladder to deploy in the event of a release.

The Emergency Information Form (in case of a spill or other emergency) was completed and prominently posted inside
the facility during the site visit. Dedicated spill clean-up materials were also available on site.

The following is a summary of $1.99 Dry Clean X-Press'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.

2. An operation manual for the wastewater treatment equipment was not made available to the Department.

3. Spill containment was not installed under and around the wastewater treatment equipment.

NESHAP VIOLATIONS - 40 CFR Part 63 Subpart M
None

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

NSPS VIOLATIONS - 40 CFR Part 60, Subpart JJJ
None

(V) CONCLUSIONS: Based on observations documented by the DSCA Inspector during the November 2, 2012
inspection, $1.99 Dry Clean X-Press 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.
(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) [15 NCAC 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.

NESHAP - 40 CFR Part 63 Subpart M
None

RCRA- Hazardous Waste Regulations: 40 CFR Part 261 - 262
None

NSPS - 40 CFR Part 60, Subpart JJJ
None

(VI) ENFORCEMENT HISTORY (Penalties): None

(VII) RECOMMENDATIONS: A DSCA Compliance Program Checklist (#00401) was issued to Mr. Lomesh Patel,
owner of $1.99 Dry Clean X-Press, indicating the compliance issues to be addressed. The inspector provided Mr. Patel a
copy of the DSCA MMP regulations, and Mr. Patel acknowledged that he understood the regulations at the conclusion of
the inspection. Mr. Patel was instructed to respond to DSCA Compliance in writing by November 28, 2012, the actions
taken to bring about compliance. A follow-up inspection should be conducted by November 2, 2013 to confirm
compliance.