20221118DeluxeClnrs_RPT

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NORTH CAROLINA DIVISION OF WASTE MANAGEMENT Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program Inspection Report

Facility Identification
Deluxe Cleaners Facility ID: 320028C EPA Generator ID: VSQG County/FIPS: Durham/063 DSCA Cleanup ID:
Facility Data
Deluxe Cleaners 1810 Martin Luther King Parkway
Durham NC 27707 Lat: 35.96143 Long: -78.95805 SIC: 7216 / Dry Cleaning Plants, Except Rugs NAICS: 81232/ Dry Cleaning and Laundry Services (except Coin-Operated) Date of Facility Establishment: 10/23/2014
Compliance Data Inspection Date: 11/18/2022 Time In: 09:53 AM Time Out: 11:00 AM Inspector: John Stauber Operating Status: OO/Operating Compliance Codes: In Violation of MMP, NESHAP Action Code: 01/Inspection
Contact Data Classification Data Service Type: Full Service (Active) Solvent: Perchloroethylene System: Dry-to-Dry Installation Date: 2014 Installation Category: New Consumption Category: Small HW Generator Status: VSQG
Facility Contact Diana Guzman 1810 Martin Luther King Parkway Durham, NC 27707
[phone] [phone]
Facility Owner Deluxe Cleaners Victor Ize-Iyamu 571 Buckingham Court Cary, NC 27511
[phone] [phone]
Property Owner Biggerstaff & Crawley King LLC William R. Crawley 123 Crawford Rd.
Hillsborough, NC 27278 [phone]
Inspector’s Signature:
Date of Signature: 22 November 2022
Comments:
Poor housekeeping. Poor WWTU maintenance. Smell of perc in room.

(I) DIRECTIONS: From Raleigh, take Wade Avenue west to I-40 W. Take exit #278 for NC-55, turn left onto NC-55 and go 1.6 miles. Turn left onto Martin Luther King Pkwy and go 4.8 miles. The facility will be on the right. (II) FACILITY HISTORY: Deluxe Cleaners was established by Mr. John (Jong) Park on October 23, 2014 (date business opened). The corporate owner of the business is STO, Inc. (Sun Ok Hellner is the registered agent). The building housing the business was built in 1995 and Biggerstaff & Crawley King LLC is the current property owner. Mr. Park said a computer business was in the building prior to him establishing the dry-cleaning business. In March of 2020 the facility was bought
by Mr. Victor Ize-Iyamu. The facility services five pickup stores, Deluxe Cleaners in Cary, Raleigh, Chapel Hill, Carrboro and Durham. Solvent History: Solvent Dates Used
Perchloroethylene 10/20/2014 to Present

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Previous Inspections:
Date Visit Type Violation Type(s) Worst Violation(s) Action(s) Taken Response Due Received Date Inspector
2/24/2022 Inspection MMP, NESHAP, RCRA
Improper disposal of waste, Improper maintenance of WWTU, Improper use of WWTU, NESHAP Procedural Violations, NESHAP Recordkeeping Violations, No spill cleanup materials, No WWTU records, WWTU (no manual)
CHKLST sent on 2/24/22
None N/A or Not Rec'd John Stauber
10/2/2018 Inspection MMP, NESHAP, RCRA
Improper disposal of waste, Inadequate spill containment, NESHAP Recordkeeping Violations, No spill containment (sep water container), No WWTU records, Unsealed waste containers
NOVNRE sent on None N/A or Not Rec'd Aram Kim
10/2/2018 Inspection MMP, NESHAP, RCRA
Improper disposal of waste, Inadequate spill containment, NESHAP Recordkeeping Violations, No spill containment (sep water container), No WWTU records, Unsealed waste containers
CHKLST sent on 10/3/2018
None N/A or Not Rec'd Aram Kim
2/10/2017 Inspection MMP, NESHAP NESHAP Procedural Violations, NESHAP Recordkeeping Violations, No WWTU records
NOV sent on 2/23/2017
3/16/2017 3/21/2017 Aram Kim
2/10/2017 Inspection MMP, NESHAP NESHAP Procedural Violations, NESHAP Recordkeeping Violations, No WWTU records
CHKLST sent on 2/10/2017
None N/A or Not Rec'd Aram Kim
11/18/2015 Inspection MMP, NESHAP NESHAP Recordkeeping Violations, No spill containment (specify), Unsealed waste containers
NOV sent on 12/7/2015
12/31/2015 1/5/2016 Jack Kitchen
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11/18/2015 Inspection MMP, NESHAP NESHAP Recordkeeping Violations, No spill containment (specify), Unsealed waste containers
CHKLST sent on 11/18/2015
None N/A or Not Rec'd Jack Kitchen
2/11/2015 Initial Inspection MMP, NESHAP NESHAP Recordkeeping Violations, No spill containment (vac pump condensate containers), Unsealed waste containers
NOV sent on 3/2/2015 3/23/2015 3/25/2015 Pam Moore
2/11/2015 Initial Inspection MMP, NESHAP NESHAP Recordkeeping Violations, No spill containment (vac pump condensate containers), Unsealed waste containers
CHKLST sent on 2/11/2015
None N/A or Not Rec'd Pam Moore
11/6/2014 Outreach Training Visit
MMP No spill containment under separator water container
CHKLST sent on 11/6/2014
12/4/2014 N/A or Not Rec'd Pam Moore
Complaints: None DSCA Sampling: None (III) FACILITY CLASSIFICATION:
NESHAP INSTALLATION CATEGORY – New: Deluxe Cleaners utilizes a fourth Generation dry-to-dry dry-
cleaning machine that was installed in 2014. Since the dry-cleaning machine was installed after December 9, 1991, the dry-cleaning machine is classified as a 'New' machine installation. 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 4th Union L750 U2000 A2-M9-422C 1999 10/20/2014 N/A Perchloroethylene yes
NESHAP SOURCE CATEGORY - SMALL: Deluxe Cleaners is classified as a Small Area Source because it purchased less than 140 gallons of perc during the previous 12-month period. Based on a review of the receipts for the
past year, Deluxe Cleaners purchased no perc in the last 12 months. HAZARDOUS WASTE GENERATOR CATEGORY - VSQG: Deluxe Cleaners 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. Deluxe Cleaners 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 hazardous waste generated was transported to Extox Industries Inc. in Mississauga, ON, Canada (EPA ID# MOE# A680065 (EBR# IA8E0593)). No hazardous waste manifests were on site nor available for review. Approximately 21 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 January 24, 2018, when a total of 380 pounds of hazardous waste were transported off site (filters & liquid waste). Two partially
full 15-gallon drums of hazardous waste were 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.
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(IV) INSPECTION SUMMARY: On November 18, 2022, John Stauber, Compliance Inspector with the North Carolina Division of Waste Management, Dry Cleaning Solvent Cleanup Act (DSCA) Program, conducted a Compliance Inspection
at Deluxe Cleaners (photo 1). The inspector met with Victor Ize-Iyamu, 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 that was observed during the previous inspection, a Union L750 U2000 4th generation dry-cleaning machine (photo 2 and 3). Mr. Ize-Iyamu said that the machine is only operated on (some) Friday mornings for one load each week. He said that he performs mostly wet cleaning at this facility. The dry-cleaning
machine was observed in operation at the time of the inspection, and there was only one garment being cleaned. The inspector smelled perc in the room and his halogen detector signaled with lights and sounds for a positive detection of halogenated vapors. Vapors were detected behind the machine, above the recouper (photo 4). The inspector instructed the owner to take care of this right-away, and a response will be necessary to confirm that the leaks have been repaired. About 1.5 gallons of separator water was being stored behind the dry-cleaning machine. Mr. Ize-Iyamu said that it had been there for some time. The inspector reminded him that the container should have a lid on it and be within spill containment when it contained water. Mr. Ize-Iyamu had his halogen leak detector on site. He powered it on and confirmed it was operational (photo 5).
The spotting table is located to the right of the dry-cleaning machine (photo 6). There was no Picrin found on the spotting table itself, but there was a gallon-sized bottle of Picrin below the nearby sink (photo 7). The owner said they rarely use
Picrin. The inspector reminded the owner of the dangers of Picrin spotting agent and that it contains PCE. The facility’s central vacuum is located inside the boiler room (photo 8). The boiler room is on the lower level of the
building. No vacuum condensate was in the collection container. The facility’s JU Smart Mist WWTU is in the boiler room (photo 9). The nozzle is in the small, louvered cutout in the
exterior wall that allows for ventilation within the boiler room. The owner had the WWTU unit repaired after the last DSCA inspection, but he has not replaced the internal filter since that repair. The inspector provided contact information for purchase of new filters, and a response will be necessary to confirm that the filters have been changed.
The hazardous waste storage area is behind the dry-cleaning machine (photos 10and 11). Housekeeping in the area was poor. Six waste containers were observed during the inspection; 2 short and round filter containers (one empty, one full), 4 plastic 20-gallon waste containers (two partially full and two empty), and one 15-gallon metal drum which was empty and sitting on a wooden chair. These appeared to be the same containers that were present during the last DSCA inspection. The drums containing waste were sealed, yet there were no labels designating the hazardous waste. The inspector discussed the importance of having the containers marked, and the owner said that he understood.
No perc purchase receipts, nor waste disposal manifests were on site nor were available for review. Mr. Ize-Iyamu said that he has not had a waste pickup since the last DSCA inspection that occurred in 2018. He commented that the facility did not purchase any perc this year. He did not have any receipts for the purchase of replacement WWTU filters. The inspector
stressed the importance of this requirement. The inspector said that he would send contact information for purchase of replacement filters via email to the owner later this day.
Required recordkeeping in the 2022 DSCA Compliance Calendar was complete. There were no other calendars to review. Past reports note that recordkeeping had been poor in the past, and the facility has resumed the logs and recordkeeping for the 2022 year. The operation manual of the dry-cleaning machine was kept on site near the dry-cleaning machine. The
inspector has emailed a copy of the manual for the SmartMist WWTU, which the owner has confirmed receiving. The emergency spill cleanup materials were on site, and the emergency information form was posted.
The following is a summary of Deluxe Cleaners’ compliance with respect to the DSCA Required Minimum Management Practices provided in 15A NCAC 02S.0202, National Emission Standards for Hazardous Air Pollutants (NESHAP) found in 40 CFR Part 63 Subpart M and Resource Conservation, and Recovery Act (RCRA) referenced in 40 CFR part 261.5 and 262.
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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. Spill containment was not installed under and around the waste solvent storage containers. NESHAP VIOLATIONS - 40 CFR Part 63 Subpart M
1. Dry cleaning machine leaks were not repaired within the required time period.
RCRA VIOLATIONS - Hazardous Waste Regulations: 40 CFR Part 262.34 1. The facility is a hazardous waste Very Small Quantity Generator (VSQG) and the hazardous waste drums were not clearly identified with their respective accumulation start dates.
2. The hazardous waste drums were not labeled with the words "Hazardous Waste" or with other words that identify the contents of the containers. (V) CONCLUSIONS: Based on observations documented by the DSCA Inspector during the November 18, 2022 inspection, Deluxe Cleaners 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)(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 63.322 (m) Failure to repair all detected leaks within 24 hours and/or failure to initiate either a written or verbal order for repair parts within 2 working days of detecting such a leak, and/or failure to install repair parts within 5 working days after receipt [63.322(m)].

RCRA- Hazardous Waste Regulations: 40 CFR Part 261 - 262
262.34
(a)(2) Failure to label the hazardous waste containers with the accumulation start date or the date in which
hazardous waste was first added to each hazardous waste container [262.34(a)(2)].
(c)(1)(ii) Failure to mark containers either with the words “Hazardous Waste” or with other words that identify the contents of the containers [262.34(c)(1)(ii)].
(VI) ENFORCEMENT HISTORY (Penalties): None (VII) RECOMMENDATIONS: A DSCA Compliance Program Checklist (#999) was issued to Mr. Victor Ize-Iyamu, Owner of Deluxe Cleaners, indicating the compliance issues to be addressed. Mr. Ize-Iyamu was instructed to respond to DSCA Compliance in writing by December 09, 2022, the actions taken to bring about compliance. A follow-up inspection should be conducted by November 18, 2023 to confirm compliance.
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(VIII) PHOTOGRAPHS:
Photo 1: The store front. Facility is on the right side.

Photo 3: The rear of the dry-cleaning machine
Photo 2: The dry-cleaning machine

Photo 4: Halogen detector and positive detection signal
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Photo 5: The facility’s halogen detector
Photo 7: Bottle of Picrin under the sink

Photo 6: The spotting table
Photo 8: The central vacuum on the lower level
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Photo 9: The facility’s wastewater treatment unit
Photo 11: The waste storage area

Photo 10: The waste storage area