20150507$199DryCleanXPress_RPT

NORTH CAROLINA DIVISION OF WASTE MANAGEMENT
Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program
Inspection Report
Date: 5/8/2015

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: 5/7/2015
Time In: 09:20 AM Time Out: 10:25 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: 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
Jaimata LLC
3603 Davis Dr.
Morrisville, NC 27560
[phone]
[phone]
Property Owner
Davis Drive 3607 LLC
4400 Triland Way
Cary, NC 27518-2777

Inspector’s Signature:

Date of Signature: 5/12/2015

Comments:

(I) DIRECTIONS: From Raleigh take Wade Ave west and merge onto I-40 West. Take exit 284 for Airport Blvd and
keep left at the fork. 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 Bethany Village
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 operated by
Mr. Lomesh Patel since its establishment in November 2009 (corporate owner is Jaimata LLC, Hitesh R. Gandhi is the
registered agent and Lomeshkumar J. Patel is a manager). The facility is located in the Bethany Village Shopping Center
between My Eye Dr. and a vacant retail space. The facility is open from 7 am to 7 pm M-F and 8 am to 5 pm on
Saturday, and services one pickup location, Ace Cleaners (2430 Southwest Cary Pkwy) Cary.

Solvent History:
Solvent Dates Used
Ecosolve 11/1/2009 to Present

Previous Inspections:
Date Visit Type Violation
Type(s)
Worst Violation(s) Action(s)
Taken
Response
Due
Received
Date
Inspector
3/12/2013 Initial
Inspection
In
Compliance
N/A CHKLST
sent on
3/12/2013
None N/A Pam
Moore
11/2/2012 Outreach
Training
Visit
MMP No spill containment
(WWTU), No
WWTU
records/manual
CHKLST
sent on
11/2/2012
11/28/2012 11/28/2012 Alicia
Roh

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?
2 Dry-to-
Dry
n/a Union HL 860 666-H9-
0441
2009 11/1/2009 N/A Ecosolve yes
1 Dry-to-
Dry
n/a Union HL 860 666-B9-
0433
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 solvent waste on site.
$1.99 Dry Clean X-Press 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
hazardous waste manifests were on site and available for review. Approximately 15 pounds of hazardous waste are
generated per month. In the past 12 months, no facility-generated waste was transported off site. The last waste
pickup occurred on May 1, 2014, when a total of 550 pounds of hazardous waste were transported off site (Liquid
waste). One partially full 55-gallon drum of hazardous waste was observed on site at the time of the inspection
(approx. 180 lbs.). The facility utilizes an onsite wastewater treatment unit (WWTU) to dispose of facility-generated
contact water.

(IV) INSPECTION SUMMARY: On May 7, 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 $1.99 Dry Clean X-Press. The inspector met with Sam Patel, store employee, and Lomesh Patel, store owner, who
provided the inspector access to the facility's equipment and available records.

The facility continues to use the same two dry cleaning machines (pictures 1 & 2) observed during previous inspections,
as listed above. The machines are normally operated from 6:45 a.m. to 3:30 p.m. Monday through Friday and were
observed in operation. No problems were observed with either machine. Separator water is collected in containers
located in spill containment. No water was observed in the containers and a total of 1.5 gallons of separator water is
generated per day and is treated onsite. The solvent filters are changed every three months and are drained more than 8
hours prior to removal and disposal.

One 55-gallon drum of Ecosolv solvent (picture 3) was stored onsite in spill containment (with an expandable bladder).
The facility purchases one 55-gallon drum of solvent about every 3 months from Phenix Supply.

The hazardous waste storage (picture 4) area is located near the presses. One 55-gallon waste drum (labeled non-
regulated waste) is stored in spill containment (with an expandable bladder) was about 1/3 full. The inspector noticed a
box of hangers was placed in front of the bladder attachment which could prevent the full deployment of the bladder in
case of a drum leak. The inspector pointed this out to Sam Patel who quickly moved the box and instructed the employees
not to place any box or container in front of the spill containment unit for the waste drum.

Facility generated contact water is treated onsite in a Galaxy mister (picture 5) located next to machine #1 in spill
containment. The inspector was told that the filters are changed every 4 to 5 months and the last filter change recorded in
the WWTU log was in January 2015. Based on the amount of contact water generated per month, about 40-45 gallons,
the filters on the mister should be changed every 9 to 10 months to comply with the manufacturer’s recommendation. The
misting nozzle is mounted on the edge of an awning outside the facility. The inspector observed that one of the lines to
the misting nozzle was broken (picture 6) and pointed this out to Mr. Patel. The inspector told Mr. Patel to have the line
repaired prior to using the mister, and Mr. Patel said he would have Sam Patel repair the broken line later in the day. The
facility has been completing the WWTU inspection log provided to Mr. Patel during the previous inspection. The
inspector gave Mr. Patel a copy of the petroleum compliance calendar which contained a bi-monthly WWTU inspection
log.

The vacuum pump is located in the boiler room. Pump condensate is drained into a container and treated in the Galaxy
mister. No condensate was observed in the container and the facility generates about one gallon of condensate per day.

The operation manual for the WWTU was on site, an emergency information form was completed and posted and spill
cleanup material (pig mats) was stored onsite.

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. Wastewater treatment equipment was not properly maintained (nozzles), which potentially allowed water
containing dry-cleaning solvent to be discharged into the environment.

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 May 7, 2015 inspection,
$1.99 Dry Clean X-Press is currently in violation of the following regulations:

MMPs - 15A NCAC 02S.0202
(b)(1) Failure to prevent solvent waste from discharging into the environment. [15 NCAC 0202 (b)(1)].
Wastewater treatment units (misters/evaporators) must be leak-free, properly operated, and
maintained according to the manufacturer’s recommendations to ensure that solvent is not released
into the environment. The misting nozzle of your wastewater treatment unit is not operating
properly, which may lead to deposition of wastewater and a potential release of wastewater into the
environment.

(VI) ENFORCEMENT HISTORY (Penalties): None

(VII) RECOMMENDATIONS: A DSCA Compliance Program Checklist (#01110) was issued to Mr. Sam Patel, cousin
of the owner of $1.99 Dry Clean X-Press, indicating the compliance issues to be addressed. Mr. Patel was instructed to
respond to DSCA Compliance in writing by May 28, 2015, the actions taken to bring about compliance. A follow-up
inspection should be conducted by May 7, 2016 to confirm compliance.