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HomeMy WebLinkAbout20240625ACW205_RPT1 of 10 NORTH CAROLINA DIVISION OF WASTE MANAGEMENT Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program Inspection Report A Cleaner World #205 Facility ID: 920060C EPA Generator ID: NCR000004648 County/FIPS: Wake/183 DSCA Cleanup ID: Facility Data A Cleaner World #205 2321 Davis Drive Cary NC 27519-8480 Lat: 35.789172 Long: -78.847456 SIC: 7216 / Dry Cleaning Plants, Except Rugs NAICS: 81232/ Dry Cleaning and Laundry Services (except Coin-Operated) Date of Facility Establishment: Compliance Data Inspection Date: 6/25/2024 Time In/Out: 9:22 am - 10:47 am Inspector: Rachel Clarke Operating Status: OO/Operating Compliance Codes: In Compliance Action Code: 01/Inspection Contact Data Classification Data Service Type: Full Service (Active) Solvent: Perchloroethylene System: Dry-to-Dry Installation Date: 2005 Installation Category: New Consumption Category: Small VSQG Mike Smith 2321 Davis Drive Cary, NC 27519-8480 (919) 461-1722 Facility Owner Mike Smith 2321 Davis Dr. Cary, NC 27519 (919) 380-7771 Property Owner Jay T. Properties LLC 2019 Eastchester Dr. High Point, NC 27265 Inspector’s Signature:Comments: No violations were observed. (I) DIRECTIONS: From Raleigh take Wade Avenue West to I-40 W. Take Exit 287 for Harrison Ave and turn left onto N Harrison Avenue. Travel 2.5 miles. Turn right onto NW Maynard Road and travel 2.3 miles. Turn right onto High House Road and travel 2.3 miles. Turn left onto Davis Drive and the facility is on the right in the Cornerstone Village shopping center. (II) FACILITY HISTORY: In 1996, Mike Smith established A Cleaner World #205. Mr. Smith is the current owner, and he is the Vice President for ACW Management. The facility is open from 7:00 a.m. to 7:00 p.m. Monday through Friday and from 8:00 a.m. to 5:00 p.m. on Saturday. The facility is stand-alone and does not service any pickup stores. Solvent History: Solvent Dates Used Previous Inspections: 6/1/2023 Inspection In Compliance sent on Clarke Compliance sent on Clarke Compliance sent on Moore Compliance sent on Moore 2 of 10 Date Visit Type Violation Type(s) Worst Violation(s) Action(s) Taken Response Due Received Date Inspector 3 of 10 Compliance sent on Moore Compliance sent on Moore Inspection sent on Moore Training on Complaints: None DSCA Sampling: None (III) FACILITY CLASSIFICATION: NESHAP INSTALLATION CATEGORY – New: A Cleaner World #205 utilizes a 4th-generation dry-to-dry dry-cleaning machine that was installed in 2005. 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 1 Dry-to-Dry 4th Columbia T.D. Mach2.50 05B6379 2005 2005 N/A perc yes NESHAP SOURCE CATEGORY - SMALL: A Cleaner World #205 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, A Cleaner World #205 purchased 60 gallons of perc from N.S. Farrington Supply Company in the last 12 months. HAZARDOUS WASTE GENERATOR CATEGORY - VSQG: A Cleaner World #205 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. A Cleaner World #205 has contracted with Safety Kleen (EPA ID# TXR000050930) 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 Safety Kleen in Lexington, SC (EPA ID# SCD077995488). Three years of hazardous waste manifests were on site and available for review. Approximately 66 pounds of hazardous waste are generated per month. In the past 12 months, 613 pounds of facility-generated waste were transported off-site. The last waste pickup occurred on April 18, 2024, when 248 pounds of liquid hazardous waste were transported off-site. Several 15-gallon drums of hazardous waste were observed on-site at the time of the inspection (approx. 200 lbs.). The facility utilizes an onsite wastewater treatment unit (WWTU) to dispose of facility-generated contact water. (IV) INSPECTION SUMMARY: On June 25, 2024, Rachel Clarke, Compliance Inspector, with the North Carolina Division of Waste Management, Dry Cleaning Solvent Cleanup Act (DSCA) Program conducted a Compliance Inspection at A Cleaner World #205 (picture 1). The inspector met with Mike Smith, the store owner, who provided the inspector with access to the facility's equipment and available records. Mr. Smith told the inspector his facility manager quit, and he was looking for a replacement. Dry-Cleaning Machine The facility continues to use the same dry-cleaning machine, a Columbia ilsa TD Mach2.50 dry-cleaning machine observed during the previous inspection (pictures 2 -7). The machine is operated Monday through Friday from 7 a.m. to noon to clean 4 of 10 five to six loads. Mr. Smith started a new load a few minutes after the inspector arrived on-site. The dry-cleaning machine’s two solvent tanks held approximately 68 gallons of perc solvent. The dry-cleaning machine has an automatic clean-out system for the distillation unit. The still is plumbed directly to a hazardous waste drum in spill containment located beside the dry-cleaning machine (picture 5). The attached drum contained a small amount of still waste. The machine’s separator water is plumped directly into a 5-gallon closed bucket located within the machine’s spill containment pan (picture 7). The container held about 2.5 gallons of separator water. Mr. Smith said the machine generates 3 to 4 gallons of water per week. The inspector used her halogen detector to inspect the machine’s front and rear components. The inspector's detector did not alert to the presence of perc vapors. The inspector asked Mr. Smith to see his halogen detector. Mr. Smith retrieved his detector from an office and turned it on to show that it was in working order. The inspector was able to see the refrigerated condenser’s exit temperature at the end of the dry cycle and it was 15°F (picture 8). Mr. Smith told the inspector he had replaced the compressor on the dry-cleaning machine a short while ago and since that time, he has seen the exit temperature go as low as12°F. Spotting Table A Forenta brand spotting table equipped with steam and a waste collection container sits slightly in front of and to the side of the dry-cleaning machine (picture 9). The spotting table’s waste collection container has a dark liquid in the bottom (picture 10). Mr. Smith said the table does not generate much waste and he pours the table’s waste into a waste drum a few times a year. Spotting agents are stored on the bottom shelf of a small, angled shelf that sits in front of the dry-cleaning machine. Spotting agents on-site are Mulsolite, ProTeen, Pyratex, P.O.G (Stamford), Trik, PSR II, Rust Go, and Spol. Vacuum The vacuum is equipped with a hand-wheel sillcock valve for manual draining and sits near the presses (picture 11). An empty stained plastic rectangular bin was under the drain pipe (picture 12). Mr. Smith said the vacuum doesn’t generate much liquid. He checks it regularly and if he gets any water, he pours it into the WWTU. Wastewater Treatment Unit (WWTU) Facility-generated contact water is treated on-site using a Kleen-Rite mister. The mister sits behind the dry-cleaning machine within spill containment (picture 13). The unit’s misting nozzles are mounted on a metal frame which is placed outside a window that sits directly above the WWTU when the WWTU is in operation (picture 14). Mr. Smith told the inspector that he ordered and had received a new nozzle for the mister. He said the seal on the nozzle was worn and it was affecting the water pressure going to the nozzle. He said he planned to install the nozzle that afternoon. The filters on the mister are changed every 3 months and the change dates are recorded in the compliance calendar. The last filter change recorded in the calendar was on March 24, 2024. Mr. Smith said that when he installed the new nozzle, he was also going to change the carbon cartridges in the WWTU. Replacement carbon cartridges are stored on-site. Hazardous Waste Accumulation Areas The facility stores its hazardous waste on two spill containment trays (pictures 5 and 15). All drums containing waste are labeled and sealed. No perc vapors were detected by the inspector’s halogen detector. The inspector estimated that the facility had about 200 pounds of hazardous waste on-site. • Tray 1 sits beside the dry-cleaning machine and contains three 15-gallon drums, One drum is full of still waste, one drum is empty, and the drum connected to the dry-cleaning machine’s distillation unit has about 8 to 10 pounds of still waste in the bottom (picture 5). • Tray 2 sits beside the central vacuum. On this tray are two 30-gallon filter drums used for spent solvent filters and dry-cleaning machine lint. One drum contains filters and lint, and the other drum is empty (picture 15). 5 of 10 Recordkeeping The facility has more than five years of DSCA Compliance Calendars available for review (picture 16). The facility maintains labeled file folders for its perc purchase receipts, WWTU filter purchase receipts, and Waste Manifests. The facility has more than five years of perc purchase receipts and more than three years of waste manifests and WWTU filter purchase receipts on-site and available for review (pictures 18, 19, and 20). The 5-year perc purchase calculation log, the 12-month running total perc purchase log, the dry-cleaning machine inspection log, and the hazardous waste inspection log in the DSCA compliance calendars are complete. The date of the last WWTU filter change (3/24/24) is recorded in the calendar (picture 20). The operation manuals for the dry-cleaning machine and the WWTU are on-site and available for review. Emergency Information Form An emergency information form is completed, laminated, and posted on a bulletin board near the stairs to the upper level (picture 21). Spill Clean-up Materials Spill Clean-up materials in the form of absorbent powder are stored in a large trash can that sits between the spotting table and the second hazardous accumulation area (picture 22). There were also stacks of cotton towels stored on a shelf behind the dry-cleaning machine (picture 23). Miscellaneous A Shop-Vac brand vacuum is used to clean lint from the dry-cleaning machine. Mr. Smith said he always puts the contents of the vacuum into a waste drum. The vacuum was stored in a corner near the WWTU (picture 24). (V) CONCLUSIONS: Based on observations documented by the DSCA Inspector during the June 1, 2023 inspection, A Cleaner World #205 is currently in compliance with applicable regulations. MMPs - 15A NCAC 02S.0202 NESHAP - 40 CFR Part 63 Subpart M RCRA- Hazardous Waste Regulations: 40 CFR Part 261 - 262 (VI) ENFORCEMENT HISTORY (Penalties): None (VII) RECOMMENDATIONS: A DSCA Compliance Program Checklist was issued to Mr. Mike Smith, owner of A Cleaner World #205, indicating any compliance issues to be addressed (no response required). Mr. Smith was instructed to take the necessary actions to maintain continued compliance at A Cleaner World #205. A follow-up inspection should be conducted by June 25, 2025, to confirm compliance. A Cleaner World #205 June 25, 2024 2321 Davis Drive Cary, NC 27519-8480 6 of 10 Picture 1: A Cleaner World #205 storefront, parking, and drive-thru lane. Picture 3: Label on the Columbia Ilsa dry-cleaning machine. Picture 2: Columbia Ilsa TD Mach2.5D dry-cleaning machine installed within adequate spill containment and utilizing perc solvent. Picture 4: Distillation unit with the still cleanout system attached. A Cleaner World #205 June 25, 2024 2321 Davis Drive Cary, NC 27519-8480 7 of 10 Picture 5: View of the distillation cleanout piping and the connected 15-gallon waste container. The drum on the left is full of still waste. The drum in the middle is empty. Picture 7: Separator water collection container. The machine generates 3 to 4 gallons of water per week. Picture 6: Rear view of the dry-cleaning machine. Picture 8: The refrigerated condenser exit temperature was 15°F at the end of the drying cycle. A Cleaner World #205 June 25, 2024 2321 Davis Drive Cary, NC 27519-8480 8 of 10 Picture 9: A Forenta brand spotting table equipped with steam, an internal vacuum, and a waste collection container. Picture 11: The central vacuum and its condensate collection container. Picture 10: The spotting table’s waste collection container contained lint and a couple of inches of dark liquid at the bottom. Picture 12: The condensate collection container was stained and empty. A Cleaner World #205 June 25, 2024 2321 Davis Drive Cary, NC 27519-8480 9 of 10 Picture 13: Kleen-Rite Hydro Mist WWTU stored on a spill containment tray. Picture 15: The second hazardous waste accumulation area contains two sealed and labeled 30-gallon filter drums. One drum contains spent filters, and the other is empty. Picture 14: WWTU misting nozzles. One nozzle was not operating properly. The owner had the replacement part and was going to repair the WWTU. Picture 16: The facility maintained all required recordkeeping on-site and available for review. A Cleaner World #205 June 25, 2024 2321 Davis Drive Cary, NC 27519-8480 10 of 10 Picture 17: The 5-year perc purchase log was maintained and up to date. Picture 19: The most recent hazardous waste pick-up was on April 18, 2024. Picture 18: The most recent perc solvent purchase was on April 10, 2024. Picture 20: The most recent WWTU filter change was on March 28, 2024. Mr. Smith said he would be changing the current WWTU filters by June 30, 2024 A Cleaner World #205 June 25, 2024 2321 Davis Drive Cary, NC 27519-8480 11 of 10 Picture 21: The Emergency Information form is laminated and posted on a bulletin board near a stairway. Picture 23: Cotton towels are stored behind the dry-cleaning machine. Picture 22: The facility keeps Hi-Flow filter powder in a trash can to use as spill cleanup material. Picture 24: A Shop-Vac is used to clean the lint from the dry-cleaning machine. The vacuum contents are disposed of in a hazardous waste drum.