20211102$199DryCleanXPress_RPT

NORTH CAROLINA DIVISION OF WASTE MANAGEMENT Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program
Inspection Report
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: 35.8212999998 Long: -78.8487 SIC: 7216 / Dry Cleaning Plants, Except Rugs NAICS: 81232/ Dry Cleaning and Laundry Services (except Coin-Operated) Date of Facility Establishment: November 2009
Compliance Data Inspection Date: 11/2/2021 Time In: 8:44 AM Time Out: 10:23 AM Inspector(s): Rachel Clarke Operating Status: OO/Operating Compliance Codes: In Violation of MMP Action Code: 00/Compliance Inspection
Contact Data Classification Data Service Type: Full Service (Active) Solvent: Ecosolv System: Dry-to-Dry Installation Date: 2009 Installation Category: N/A Consumption Category: N/A HW Generator Status: VSQG
Facility Contact
Lomesh Patel 3603 Davis Drive, Ste. 103 Morrisville, NC 27560 [phone]
Facility Owner
Jaimata LLC Lomesh Patel 3603 Davis Drive, Ste. 103 Morrisville, NC 27560 [phone](919)995-5038
Property Owner
Davis Drive 3607 LLC 4400 Triland Way Cary, NC 27518-2777
Inspector’s Signature:
Date of Signature: November 9, 2021
Comments:
Vacuum condensate released into a floor drain in the boiler room.
Inspection Checklist Response required by 11/23/2021,
(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 Road. Take the 1st left ontoMcCrimmon Pkwy. Turn left onto Davis Drive. The facility will be on the right, in the Bethany Village shopping center atthe intersection with Morrisville Carpenter Road.
(II)FACILITY HISTORY: $1.99 Dry Clean X-Press (now $2.17 Dry Clean X-Press) is a petroleum solvent dry cleaningplant that has been owned and operated by Mr. Lomesh Patel since its establishment in November 2009. The facility is in
the Bethany Village Shopping Center beside My Eye Dr. The facility is open Monday through Friday from 7 am to 7 pmand on Saturday from 8 am to 5 pm. The facility services one pickup location, Ace Cleaners (2430 Southwest Cary Pkwy)in Cary.
Solvent History:
Solvent Dates Used
Ecosolv 2009 to Present
Previous Inspections:
Date Visit Type Violation Type(s) Worst Violation(s) Action(s) Taken Response Due Received Date Inspector
8/31/2017 Inspection In
Compliance
N/A CHKLST
sent on 8/31/2017
None N/A Pam
Moore
5/24/2016 Inspection In
Compliance
N/A CHKLST
sent on 5/24/2016
None N/A Pam
Moore
5/7/2015 Inspection MMP Improper maintenance of WWTU (one of the
lines to the misting nozzle was broken)
CHKLST sent on 5/7/2015
5/28/2015 5/18/2015 Pam Moore
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 11/20/2012 Alicia
Roh
Complaints: None DSCA Sampling: None (III) FACILITY CLASSIFICATION:
NSPS INSTALLATION CATEGORY – Applicable: $2.17 Dry Clean X-Press utilizes dry cleaning equipment installed in 2009 with a 120-pound drying capacity (2 Union 60 lbs. machines). 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 2009 N/A Ecosolv yes
2 Dry-to-Dry n/a Union HL 860 666-H9-0441 2009 2009 N/A Ecosolv yes
HAZARDOUS WASTE GENERATOR CATEGORY - VSQG: $2.17 Dry Clean X-Press is classified as a Very Small Quantity Generator (VSQG) 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. $2.17 Dry Clean X-Press has
contracted with MCF Systems of Atlanta (EPA ID# GAD981269095) to transport the facility-generated hazardous waste to a licensed Treatment Storage or Disposal (TSD) facility. The most recent non-hazardous waste generated was transported to EWS Alabama Inc. in Glencoe, AL (EPA ID# ALD981020894). Three years of non-hazardous waste
manifests were on-site and available for review. Approximately 20 pounds of hazardous waste are generated per month. In the past 12 months, the facility has not had any waste transported off-site. The last waste pickup occurred on May 30, 2019, when a total of 550 pounds of non-hazardous liquid waste were transported off-site. One almost full
55-gallon drum of non-hazardous waste was on-site at the time of the inspection (approx. 400 lbs.). The facility utilizes an on-site wastewater treatment unit (WWTU) to dispose of facility-generated contact water.
(IV) INSPECTION SUMMARY: On November 2, 2021, Rachel Clarke, Compliance Inspector, with the North Carolina
Division of Waste Management, Dry Cleaning Solvent Cleanup Act (DSCA) Program conducted a Compliance Inspection at $2.17 Dry Clean X-Press (picture 1). Neither the facility manager nor the owner was on-site, one of the press operators (hereafter referenced as “Ms. Doe”) assisted the inspector. Ms. Doe called Hitesh Gandhi, brother-in-law to the facility owner, and he arrived on-site, near the end of the inspection and answered the inspector’s questions, and attempted to fix the WWTU’s nozzle. Dry-cleaning Machines The facility continues to use the same two Union petroleum dry-cleaning machines observed during previous inspections (pictures 2-3, 7, and 9-10). The machines are normally operated Monday through Friday from 6 am to 11 am to clean 4 loads. Before the pandemic, the facility cleaned 4 loads per day per machine. Both machines were in operation and appeared to be in good working order. The inspector did not see any leaks on the components or liquid in the machines’ spill
containment trays. Dry-cleaning machine #1 contains 59 gallons of solvent and machine #2 contains 76 gallons of solvent (pictures 4-6 and 11-13). Separator water is collected in containers and treated onsite. Both machine’s separator water tanks had just been drained into containers that were sitting on the floor outside of spill containment (pictures 8, 14) Ms.
Doe said about a gallon of water is generated per week. The inspector told Ms. Doe that the separator water must be kept in spill containment and that she should place both collections containers in spill containment immediately. Ms. Doe was able to find a 5-gallon bucket to put the 1-gallon bucket into, but she couldn’t find anything that would hold the other collection
container (5-gallon bucket). Ms. Doe did not know how often the solvent filters are changed or how they are discarded. Spotting Table The spotting table is near the presses and is equipped with a waste collection container (pictures 15 – 16). Spotting agents used on-site are Pyratex LV, RustGo, SpotLess, StreePro, Mulosite, WetDry, InkGo, and PSR (picture 17) A 1-gallon container of Picrin is on-site. Ms. Doe said that she doesn’t use Picrin, she uses Pyratex. A 2019 invoice for a gallon container of Picrin is on-site (picture 18). The inspector told Ms. Doe that she must always dispose of the spotting table’s waste into a drum for disposal by a licensed waste hauler. Ms. Doe replied that she always poures the spotting table condensate into a waste drum. Vacuum The vacuum is in the boiler room (picture 19). Pump condensate is drained from underneath the pump using a manual valve (picture 20). The inspector asked Ms. Doe how she drains the vacuum. She stated that she connects a rubber hose to the valve on the bottom and places the other end of the hole in a floor drain near the outside door of the boiler room (picture
21). The inspector informed Ms. Doe that they must never dispose of vacuum condensate down a floor drain. The inspector explained all contact water must be treated on-site using the WWTU or drummed and shipped off-site. Ms. Doe said she didn’t know that. The inspector told Mr. Gandhi what Ms. Doe had said, and he replied that when he drains the vacuum,
and he always pours the contact water into the WWTU. The inspector told Mr. Gandhi that based on Ms. Doe’s comments about how she disposes of vacuum condensate. Dry Clean X-Press violated the State’s MMP by improperly disposing of contact water. Mr. Gandhi said he would train the employees and this violation would not occur again.
Wastewater Treatment Unit The facility uses a Galaxy mister to treat facility-generated contact water (picture 22). The mister is stored within spill containment and sits beside dry-cleaning machine #1. The misting nozzle is mounted on the metal support of a large metal awning on the exterior rear of the building (picture 23). The last recorded WWTU filter change was in September 2021. The inspector asked if the WWTU had been operating properly and Ms. Doe said yes. The inspector asked Ms. Doe to put the WWTU into operation so that she could inspect the nozzle. The inspector waited a few minutes and then checked the nozzle. No mist was emitting from the nozzle. The inspector told Ms. Doe the nozzle was not misting, and she should not use it until it is repaired. Mr. Gandhi spent several minutes attempting to fix the unit. He believed there was air in the tubing that was preventing the liquid from reaching the nozzle. After the inspector had left the facility, Mr. Gandhi called her to say he had fixed the problem and asked her to return to the facility. The inspector returned to see the nozzle emitting
a faint, almost imperceptible mist. The inspector told Mr. Gandhi the nozzle should be emitting a strong visible mist and not operate the WWTU until after it is repaired.

Solvent Storage and Waste Accumulation Area The facility’s solvent and waste storage areas are together in front of dry-cleaning machine #2, near the back door (picture
24). On the left side is a full 55-gallon drum of Ecosolv petroleum solvent and on the right side is a 55-gallon drum approximately 90% full of dry-cleaning machine waste. Both drums are stored on individual spill containment trays equipped with expandable bladders. Recordkeeping Ms. Doe called Mr. Gandhi to find out where the facility keeps its calendars and receipts. The facility has DSCA calendars dating back to 2018. WWTU inspection logs and filter changes are maintained in the calendars (25 – 26). For the years between 2015 and 2020, WWTU filter changes were recorded in a separate logbook (picture 27). The facility has WWTU replacement filter purchase receipts dated 2018 and 2019 (picture 28). The inspector did not see any WWTU replacement filters on-site. A Galaxy Mister User manual is on-site (picture 29). The facility has over three years of waste manifests on-site and, available for review. The most recent manifest is dated 2019 (picture 30). Mr. Gandhi said they have not had
any waste pickups since 2019. Emergency Information form
An emergency information form is posted at a workstation near the front counter (picture 31) Spill Clean-up Materials
Spill clean-up materials (pig mats) are stored behind dry-cleaning machine #2 (picture 32). (V) CONCLUSIONS: Based on observations documented by the DSCA Inspector during the November 2, 2021, inspection of $2.17 Dry Clean X-Press is currently in violation of the following regulations: MMPs - 15A NCAC 02S.0202 (b)(1) Failure to keep solvent waste from discharging into the environment. [15 NCAC 0202 (b)(1)]. At no time shall any dry-cleaning solvent, wastes containing dry cleaning solvent, or water containing dry cleaning solvent be discharged onto land or into waters of the State, sanitary sewers, storm drains, floor drains,
septic systems, boilers, or cooling-towers. Wastewater (water containing spotting agents and solvent) that is generated during pre-cleaning, spotting, and steam press operations is collected in the clothes press vacuum pump. This collected wastewater is being released from the clothes press vacuum pump and into
a floor drain in the boiler room.
(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 the deposition of wastewater and a potential release of wastewater into the environment.
(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. Wastewater treatment unit filters must be changed, and filter changes must be documented.
Your wastewater treatment unit filters have not been changed in accordance with the manufacturer's
recommendations, which may lead to deposition of wastewater and a potential release of wastewater into the environment. No record of filter changes in 2020 or 2021.
(b)(2) Failure to maintain spill containment under and around the 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 at least 72 hours. Spill containment was not installed under or around containers storing dry-cleaning machine separator water.

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 (#03318) was issued to Mr. Hitesh Gandhi, brother-in-law to the owner of $2.17 Dry Clean X-Press, indicating the compliance issues to be addressed. The inspector provided Mr. Gandhi with a copy of the DSCA MMP regulations, and Mr. Gandhi stated that he would train the employees
and make sure they are following the regulations. Mr. Gandhi stated he would have Mr. Patel respond to DSCA Compliance in writing by November 23, 2021, the actions taken to bring about compliance.
A follow-up inspection should be conducted by November 2, 2022, to confirm compliance. (VIII) PHOTOGRAPHS:
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Picture 8: Separator water from machine 1 is in a 5-gallon bucket stored outside of spill containment.
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Picture 14: machine 2 separator water stored outside of spill containment.

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