HomeMy WebLinkAbout20150507$199DryCleanXPress_ICRSP20150518North Carolina Department of Environment and Natural Resources (NCDENR) Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program Corrective Response Form q;;cv f) $(!.
INSTRUCTIONS:
Your facility has received a DSCA Compliance Inspection. This inspection re
vealed that: I violations were found _____ no violations were found
If violations were found, you are required to respond in writing by indicating on
this form in the boxes provided (attach additional pages if necessary) the actions
you have taken to correct the violations identified by the DSCA inspector as noted
on the opposite side of this form.
Complete and return this form to the address below by � '20 t5.
Division of Waste Management � � DSCA Compliance Program -Attn: Eric Swope W i H-., �� 1646 Mail Service Center -ft>· f
Raleigh, North Carolina 27699-1646 \........__
If your facility is located in Buncombe, Forsyth, or Mecklenburg counties,
please contact the indicated local air quality program below to ensure that your
facility is in compliance with the applicable air quality (NESHAP or NSPS) regu
lations.
_ Forsyth County Environmental Affairs Department-336.703.2440
_ Mecklenburg County Air Quality -704.336.5430
_ Western NC Regional Air Quality-828.250.6777
Please be aware that civil penalties may be assessed for violations of DSCA Min
imum Management Practices (MMPs) and the applicable air quality (NESHAP
and NSPS) and hazardous waste (RCRA) regulations. Regulatory compliance is
also required to be eligible for certification into the DSCA Cleanup Program if
dry-cleaning solvent contamination is discovered at this location.
RELEASES: [MMP-15A NCAC 02S.0202(b)(l)J
a. ( )Discharging solvent onto land/water/sewer/drain/septic/boiler/cooling-tower
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EMERGENCY RESPONSE: [MMP-15A NCAC 02S.0202(b)(2)1
a. ( )MMP-Failure to maintain emergency response plan
b. ( )MMP-Emergency adsorbent spill clean-up materials not on premises
EQUIPMENT: (40 CFR/
a. ( )NESHAP-Failure to conduct leak detection inspections while dry cleaning sys
tem is operating [63.322(k)]
b. ( )NESHAP-Failure to conduct monthly leak detection inspections with halogen
leak detector [63.322(o)(l)]
c. ( )NESHAP-Failure to repair leaks within specified time interval [63.322(m)]
d. ( )NESHAP-Machine door not closed [63.322(c)]
e. ( )NESHAP-Cartridge filters drained less than 24 hours [63.322(i)]
f. ( )NESHAP-Not operating dry cleaning system in accordance w/ manufacturer(s)
specifications [ 63.322(d)]
g. ( )NSPS-Failure to install solvent recovery dryer [60.622(a)] c. ( )RCRA-Waste containers not labeled as 'Hazardous Waste' (SQG)
h. ( )NSPS-Failure to install solvent cartridge filter [60.622(b)] [262.34(c)(l)(ii)]
i. ( )NSPS-Cartridge filters drained less than 8 hours [60.622(b)] d. ( )RCRA-Waste containers not labeled with the accumulation start date (SQG)
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CONTROL DEVICES: 140 CFR/
a. ( )NESHAP-Failure to monitor refrigeration system H/L pressure readings on
weekly basis [63.323(a)(l)(i)]
b. ( )NESHAP-Failure to monitor refrigeration system condenser exit temperature on
weekly basis [63.323(a)(J)(ii)]
c. ( )NESHAP-Reference temperature sensor not within specified accuracy
[ 63.323(a)(J)(ii)]
d. ( )NESHAP-Secondary carbon adsorber not desorbed in accordance with manu
facturer's specifications [63.322(0)(2)]
e. ( )NESHAP-Failure to retain on site design specification and operating manual(s)
for each dry cleaning system and each additional control device(s) [63.324(e)]
Dry Cleaner's Response: .. 1• , " 1 � .., -;.T ', ·� ·;, � � '!' 0 ri ' ! . >; 0,_ ·l • -' "' � ' •.
SPILL CONTAINMENT: [MMP -1 SA NCAC 02S.0202(b)(2)!
a. ( )MMP-Not installed under dry-cleaning machine
b. ( )MMP-Not installed under dry-cleaning machine still I filter bank
c. ( )MMP-Not installed under waste solvent storage area
d. ( )MMP-Not installed under solvent storage area
e. ( )MMP-Not installed under wastewater treatment equipment
f. ( )MMP-Not installed under washer I reclaimer
g. ( )MMP-Not installed (other mach.components) .. ,
h. ( )MMP-Less than 110% volumetric capacity of largest tank/container
i. ( )MMP-Not adequate to contain release for at least 72 hours
j. ( )MMP-Not constructed of material impervious to solvent
k. ( )MMP-Unsealed floor drain within spill containment
Dry Cleaner's Response:
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WASTEWATER TREATMENT EQUIPMENT: IMMP-15A NCAC 02S.0202(b/(l)J
a. ( )MMP-Inadequate equipment for treatment of wastewater containing solvent
b. ( )MMP-Not operating in accordance w/ manufacturer(s) specifications
c. (}()MMP-Improper maintenance of equipment (nozzles I filters I plumbing)
Dry Cleaner's Response. l-i't1 e .fa YV' i ') v Y"°) (lu \.J-.) .f ,• Ke.J_ '
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CLOSED LOOP SOLVENT DELIVERY: IMMP 15A NCAC 02S.0202(b)(4)J
a. ( ) MMP-Not utilizing appropriate closed container solvent transfer system
STORAGE/TREATMENT/DISPOSAL: 140 CFRI
a. ( )RCRA-lmproper disposal lint filter/button trap/shop vacuum contents [261.3
(a)(2)(iv)]
b. ( )NESHAP-Solvent waste containers not sealed [63.322(])]
[262.34(a)(2)]
e. ( )RCRA-Facility does not have EPA ID# (SQG) [262.12(a)]
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RECORDKEEPING: 140 CFRI
a. ( )NESHAP-Failure to maintain control device log (5 yrs) [63.324(d)(5)]
b. ( )NESHAP-Failure to maintain leak detection log (5 yrs) [63.324(d)(3)]
c. ( )NESHAP-Failure to maintain halogen detector log (5 yrs) [63.324(d)(3)]
d. ( )NESHAP-Failure to maintain leak repair log (5 yrs) [63.324(d)(4)]
e. ( )NESHAP-Failure to record volume perc purchased each month [ 63.324(d)(J)]
f. ( )NESHAP-Failure to calculate 12 mo. running total of perc purchases on first
day of each month [63.324(d)(2)]
g. ( )NESHAP-Failure to maintain 12-mo. running total (5 yrs) [63.324(d)]
h. ( )MMP-Failure to provide operation manual for wastewater treatment unit [J 5A
NCAC 02S.0202(b)(l)]
i7'' ( ) RCRA-Failure to maintain weekly hazardous waste inspection log (SQG)
[262.34(d)(2)]
RECEIPTS:
a. ( )MMP-Waste manifests for last 3 years not available [J 5A NCAC 02S.0202(bl)]
b. ( )MMP-Wastewater treatment equipment records for last 3 years not available
[l 5A NCAC 02S.0202(bl)]
c. ( )NESHAP-Pere purchase receipts not available for 5 years [40 CFR 63.324(d)]
d. ( )Failure to pay solvent tax [G.S. §105-187.31]
Dry Cleaner's Response:
I certify under penalty of law that the a
the best of my knowledge.
Responsible Official's Name (printed) _______ _
Signature: Date: ____ _