20120913MorrisvilleDryClnrs_RPT

NORTH CAROLINA DIVISION OF WASTE MANAGEMENT
Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program
Outreach Training Visit Report
Date: 9/14/2012

Facility Identification
Morrisville Dry Cleaners
Facility ID: 920074C
EPA Generator ID: NCCESQG
County/FIPS: Wake/183
DSCA Cleanup ID: -
Facility Data
Morrisville Dry Cleaners
10970 Chapel Hill Road, Ste. 126
Morrisville NC 27560
Lat: 35.85598 Long: -78.84031
SIC: / Dry Cleaning Plants, Except Rugs
NAICS: / Dry Cleaning and Laundry Services (except Coin-Operated)
Date of Facility Establishment: 10/29/2009
Compliance Data
Inspection Date: 9/13/2012
Time In: 10:30 AM Time Out: 11:30 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: DF2000
System: Dry-to-Dry
Installation Date: 2009
Installation Category: N/A
Consumption Category: N/A
HW Generator Status: CESQG
Facility Contact
Kishan Desai
10970 Chapel Hill Road,
Ste. 126
Morrisville, NC 27560
[phone]
Facility Owner
Kishan Desai
10970 Chapel Hill Road,
Ste. 126
Morrisville, NC 27560
[phone]
Property Owner
Duke Construction Ltd
Ptnrp
Duke Realty Corp
PO Box 40509
Indianapolis, IN 46240-
0509

Inspector’s Signature:

Date of Signature:

Comments:
MMP violation(s) observed
Recommend NOV if no response to Corrective Action Letter

(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. The facility will be on the right, in the Market at
Perimeter Park.

(II) FACILITY HISTORY: Morrisville Dry Cleaners is a petroleum solvent dry cleaning plant that has been owned and
operated by Mr. Kishan Desai since its establishment in October 2009. As of September 2012, the facility was located
adjacent to "The Brunch Box" deli. Morrisville Dry Cleaners does not service any area pickup locations. The dry
cleaning equipment is operated Monday-Friday for an average of 4 loads per day, starting at 8:00 am.

Solvent History:

Solvent Dates Used
DF2000 10/29/2009 to Present

Previous Inspections: None

Complaints: None

DSCA Sampling: None

(III) FACILITY CLASSIFICATION:

NSPS INSTALLATION CATEGORY – Not Applicable: Morrisville Dry Cleaners utilizes dry cleaning equipment
installed in 2009 with a 60 pound drying capacity. Although the solvent-recovery system was installed after
December 14, 1982, the total manufacturers' rated dryer capacity was less than 84 pounds. Therefore the facility is
not 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 860 607 B9 1048 2009 10/1/2009 N/A DF2000 no

HAZARDOUS WASTE GENERATOR CATEGORY - CESQG: Morrisville Dry Cleaners 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.
Morrisville Dry Cleaners has contracted with MCF Systems of Atlanta (EPA ID# GAD981269095) to transport the
facility-generated non-regulated waste to a licensed Treatment Storage or Disposal (TSD) facility. The most recent
non-regulated waste generated was transported to Clean Harbors Recycling Services of Ohio, LLC in Hebron OH
(EPA ID# OHD980587364). Three years of waste disposal manifests were on site and available for review.
Approximately 33 pounds of non-regulated waste are generated per month. In the past 12 months, 400 pounds of
facility-generated waste were transported off site. The last waste pickup occurred on January 27, 2012, when a total
of 400 pounds of non-regulated waste were transported off site (liquid & filter waste). One partially-full 55-gallon
drum of non-regulated waste was observed on site at the time of the inspection (approx. 300 lbs). The facility does
not utilize an onsite wastewater treatment unit (WWTU) to dispose of facility-generated contact water.

(IV) INSPECTION SUMMARY: On September 13, 2012, Alicia Roh, Compliance Inspector, with the North Carolina
Division of Waste Management, Dry Cleaning Solvent Cleanup Act (DSCA) Program conducted a Compliance Inspection
at Morrisville Dry Cleaners. The inspector met with Mr. Kishan Desai, store owner, who provided the inspector access to
the facility's equipment and available records.

The dry-to-dry Union dry cleaning machine was installed within spill containment. Separator water from the dry cleaning
machine was manually drained and collected as needed. Mr. Desai stated that the contact water was disposed of in the
waste drum behind the dry cleaning machine. The muck cleanout container was observed with a small amount of
accumulated waste. Dry cleaning machine filters were changed approximately every 6 months, and disposed of in the
waste drum. The last filter change was documented on January 30, 2012.

It was brought to Mr. Desai’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. Desai stated that the vacuum press condensate was
manually drained directly into the waste drum. The vacuum pump was installed approximately 12 inches above the floor,
with a flexible hose for drainage.

The onsite solvent storage area was located behind the dry cleaning machine. One partially-full 55-gallon drum of
DF2000 was observed without spill containment. Mr. Desai stated that he would pour the remaining solvent into the dry
cleaning machine later that afternoon.

The designated waste storage area was also located behind the dry cleaning machine. The 55-gallon drum that contained
waste was not stored in spill containment. The drum was labeled as “Non-Regulated Waste” by MCF. Mr. Desai stated
that it takes approximately 6 months to fill a waste drum.

The Emergency Information Form (in case of a spill or other emergency) provided to Mr. Desai, and he completed and
prominently posted the form inside the facility during the site visit. Dedicated spill clean-up materials were available on
site.

The following records were kept onsite and were available for review: machine operation manual, waste manifests for
pickup, and Material Safety Data Sheets (MSDS) for solvents and spotting agents.

The following is a summary of Morrisville Dry Cleaner’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. Spill containment was not installed under and around the waste solvent storage containers.

2. Spill containment was not installed under and around the dry-cleaning solvent storage containers.

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

(V) CONCLUSIONS: Based on observations documented by the DSCA Inspector during the September 13, 2012
inspection, Morrisville Dry Cleaners is currently in violation of the following regulations:

MMPs - 15A NCAC 02S.0202
(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.
(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 a period of at
least 72 hours.

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

(VI) ENFORCEMENT HISTORY (Penalties): None

(VII) RECOMMENDATIONS: A Corrective Action Letter was issued to Mr. Kishan Desai, owner of Morrisville Dry
Cleaners, indicating the compliance issues to be addressed. The inspector provided Mr. Desai a copy of the DSCA MMP
regulations, and Mr. Desai acknowledged that he understood the regulations at the conclusion of the Outreach Visit.
DSCA Supervisors will determine if a Notice of Violation (NOV) will be issued to Mr. Kishan Desai after reviewing a
written response from Morrisville Dry Cleaners. A follow-up inspection should be conducted by September 13, 2013 to
confirm compliance.