20221117BostonClnrs_RPT

Boston Cleaners : 010001C Page 1 of 7

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

Facility Identification Boston Cleaners Facility ID: 010001C EPA Generator ID: NCD981863616 County/FIPS: Alamance/001 DSCA Cleanup ID: DC10009
Facility Data Boston Cleaners 2182 N Church Street Burlington NC 27215 Lat: 36.09458 Long: -79.39892 SIC: 7216 / Dry Cleaning Plants, Except Rugs NAICS: 81232/ Dry Cleaning and Laundry Services (except Coin-Operated) Date of Facility Establishment: 1965
Compliance Data Inspection Date: 11/17/2022 Time In: 08:58 AM Time Out: 10:10 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: 2008 Installation Category: NEW Consumption Category: Small HW Generator Status: VSQG
Facility Contact Brad Robbins 2182 N. Church St. Burlington, NC 27217 [phone] [phone]
Facility Owner Robbins Cleaners & Laundry, Inc. James W. Robbins Jr. PO Box 3466 Burlington, NC 27215 [phone]
Property Owner CNS Crossings Properties LLC Yahya Almanifi 4230 Niblick Rd. Pfafftown, NC 27040 [phone]
Inspector’s Signature: Date of Signature: 22 November 2022
Comments: Poor spill containment housekeeping. No batteries in the detector.
(I) DIRECTIONS: From Raleigh travel west on I-40. Take exit #148/NC-54 toward Chapel Hill/Graham. Turn right onto NC-54/E Harden St. Turn right onto E Elm St/NC-49, go 1.8 miles and turn left onto W Main St. Turn left onto N
Church St/US-70 W, go 1.1 miles and the facility is on the right in a building it shares with The Tobacco Store. (II) FACILITY HISTORY: Facility operated as Glamorama from 1972 - 1984. Boston Plaza Cleaners has been owned
and operated by James William "Bill" Robbins since January 1988. Mr. Robbins bought the facility from Charlie Wright, who operated the dry-cleaning plant from 1958 – 1988. The facility was established at a prior location in 1958 and moved to its present location when the building was constructed in 1965, according to Mr. Robbins. The facility currently shares
a structure with The Tobacco Store, which is located adjacent to the facility on the right and is also owned by Mr. Robbins. Mr. Robbins stated that the space occupied by The Tobacco Store has been occupied by Radio Shack and has also been vacant in the past. Mr. Robbins stated that the facility has always used perchloroethylene (perc). Boston Cleaners is open Monday through Friday, 7am to 6pm, and on Saturday from 8am to 1pm. A dry-to-dry, 3rd generation Forenta Miraclean 345 machine was utilized on site until 2008, when it was removed by Tri-State Equipment. The facility does not service any pick-up locations. Solvent History: Solvent Dates Used
Perchloroethylene 1965 to Present
Previous Inspections:
Date Visit Type Violation Type(s) Worst Violation(s) Action(s) Taken Response Due Received Date Inspector
9/10/2019 Inspection In Compliance N/A CHKLST sent on 9/10/2019
None N/A or Not Rec'd John Stauber
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10/12/2018 Inspection In Compliance N/A CHKLST sent on 10/12/2018
None N/A or Not Rec'd Aram Kim
5/18/2017 Follow up Inspection In Compliance N/A CHKLST sent on 5/18/2017
None N/A or Not Rec'd Pam Moore
1/30/2017 Inspection MMP, NESHAP Improper use of WWTU, Unsealed waste containers
NOVNRE sent on 1/31/2017
2/21/2017 2/16/2017 Pam Moore
1/30/2017 Inspection MMP, NESHAP Improper use of WWTU, Unsealed waste containers
CHKLST sent on 1/30/2017
None N/A or Not Rec'd Pam Moore
7/9/2015 Inspection MMP, NESHAP Improper maintenance of WWTU, No emergency response plan, No spill containment (specify), No WWTU records, Unsealed waste containers
NOV sent on 7/15/2015
8/5/2015 8/4/2015 Jack Kitchen
7/9/2015 Inspection MMP, NESHAP Improper maintenance of WWTU, No emergency response plan, No spill containment (specify), No WWTU records, Unsealed waste containers
CAL sent on 7/9/2015 None N/A or Not Rec'd Jack Kitchen
8/15/2012 Inspection MMP No WWTU records CHKLST sent on 8/15/2012
9/5/2012 N/A or Not Rec'd Jack Kitchen
8/10/2010 Follow up Inspection MMP, NESHAP -- INF sent on 8/25/2010 None N/A or Not Rec'd Jason Gill
8/10/2010 Follow up Inspection MMP, NESHAP -- NOVNRE sent on 8/26/2010
9/16/2010 9/9/2010 Jason Gill
5/24/2010 Initial Inspection -- -- CAL sent on 6/9/2010 6/16/2010 6/15/2010 Jason Gill
5/24/2010 Initial Inspection -- -- NOVNRE sent on 6/9/2010
6/30/2010 6/15/2010 Jason Gill
5/2/2007 Outreach Training Visit
-- -- CAL sent on 5/2/2007 5/23/2007 5/22/2007 Alicia Roh
Complaints: None DSCA Sampling: None (III) FACILITY CLASSIFICATION: NESHAP INSTALLATION CATEGORY – NEW: Boston Cleaners utilizes a fourth Generation dry-to-dry dry-cleaning machine that was installed in 2008. Since the dry-cleaning machine was installed after December 9, 1991, the
dry-cleaning machine is classified as a 'New' machine installation.
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Dry-Cleaning Equipment Summary

NESHAP SOURCE CATEGORY - SMALL: Boston 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, Boston Cleaners purchased 60 gallons of perc from NS Farrington Supply Company in the last 12 months.
HAZARDOUS WASTE GENERATOR CATEGORY - VSQG: Boston 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. Boston 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)). Three years of hazardous waste manifests WERE on site and available for review. Approximately 110 pounds of hazardous waste are generated per month. In the past 12 months, 60 pounds of facility-generated waste were transported off site. The last waste pickup
occurred on April 07, 2022, when a total of 60 pounds of hazardous waste were transported off site (filters & liquid waste). Nine, mostly full, 15-gallon drums of hazardous waste were observed on site at the time of the inspection (approx. 770 lbs). The facility utilizes an onsite wastewater treatment unit (WWTU) to dispose of facility-generated
contact water. (IV) INSPECTION SUMMARY: On November 17, 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 Boston Cleaners (photo 1). The inspector met with Brad Robbins, store owner, who provided the inspector access to the facility's equipment and available records. The inspector originally stopped by on 11 November and spoke with Viola Dey. She asked if I could come back then next week, saying Mr. Robbins would be here then. The facility continues to use the same dry-cleaning machine observed during previous inspections, a Realstar, 4th generation, dry-cleaning machine with adequate spill containment (photo 2 and 3). The dry-cleaning machine is typically operated 5 days each week, for an average of 2 loads per day, starting early in the morning. The machine was observed in operation, and the inspector observed the refrigerated condenser exit temperature to be 41 degrees Fahrenheit at the end of the drying cycle. Separator water was collected in a container stored within the machine’s spill pan. Approximately 1 gallon of separator water was observed, and Mr. Robbins estimated that about 2 gallons of separator water are generated per week.
The facility has a halogen detector on site and Mr. Robbins attempted to power it on for the inspector. The batteries were dead. The inspector told the owner to get the batteries changed and then send a photo to the inspector showing that the
halogen detector was working. No hits to signal detection of perc vapors occurred when the inspector used his halogen detector to check the machine. There was a small signaled detection of vapors in the separator water bucket.
The spotting table is to the left of the dry-cleaning machine (photo 4). The facility uses Picrin as a spotting agent and historically used about 1 gallon per year. Mr. Robbins said he doesn’t use it often, and he and the inspector discussed the toxicity of Picrin. The owner stated that condensate collected from the spotting board is disposed into the waste drums.
The clothes press vacuum (photo 5) is located near the dry-cleaning machine. No pump condensate was observed on site. Mr. Robbins estimated that about a quart of pump condensate is generated per week, and it is treated using the KleenRite
mister.
No Type of Machine Gen Manufacturer (Mfr) Model # Serial # Mfr Date Install Date End Date Solvent Used Observed Operating? 1 Dry-to-Dry 3rd Forenta Miraclean 345 M03D6BECKT0595345 1995 1/1/1995 1/1/2008 Perc -
2 Dry-to-Dry 4th Realstar M340 91096/0369 2008 1/1/2008 N/A Perc yes
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Facility generated contact water is treated with their KleenRite Hydro Mist onsite wastewater treatment unit (WWTU). The WWTU was located to the right side of the dry-cleaning machine, within spill containment (photo 6). The mister was
observed in-operation (photo 7). The misting nozzle is located on top of and attached to the WWTU’s water reservoir. Filters in the WWTU are changed every three months and the most recent filter change occurred on 11 September 2022. The date of the filter change was documented in the WWTU inspection log in the calendar, and the N.S. Farrington invoice
for the replacement filter purchase was kept on site. The lid was not on the WWTU unit, and the inspector discussed the need to keep the lid on the WWTU. Mr. Robbins said the lid was behind all the waste drums on the spill containment pad. He said that he would dig it out and place it on unit as he rearranges and cleans his waste storage area.
The hazardous waste storage area is located near the dry-cleaning machine (photo 8). Nine, 15-gallon, plastic waste containers were observed within spill containment, but some of the containers were not fully within the spill containment structure (photo 9). The waste containers were sealed and labeled as hazardous waste. The inspector urged the owner to clean-up the area and to have all the barrels fully within -and protected by- the spill containment structure. Five years of perc purchase receipts and three years of waste disposal manifests were kept on site, available for review. Required recordkeeping in the DSCA Compliance Calendar was complete. Emergency spill cleanup material was stored
behind the WWTU (photo 10). A multi-page Emergency Information Plan was posted on the lattice wall to the left of the dry-cleaning machine (photo 11).
The following is a summary of Boston 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. MMP VIOLATIONS - 15A NCAC 02S.0202
1. The spill containment being utilized was inadequate and incapable of preventing a release of the applicable liquid dry-cleaning solvent beyond the spill containment area for a period of at least 72 hours.
NESHAP VIOLATIONS - 40 CFR Part 63 Subpart M 1. Monthly halogen detector vapor leak inspections were not performed. RCRA VIOLATIONS - Hazardous Waste Regulations: 40 CFR Part 262.34 None
(V) CONCLUSIONS: Based on observations documented by the DSCA Inspector during the November 17, 2022 inspection, Boston Cleaners is currently in violation of the following regulations:
MMPs - 15A NCAC 02S.0202 (b)(2) Failure to install spill containment that is capable of preventing the release of the applicable liquid dry-cleaning solvent beyond the spill containment area for a period of at least 72 hours. Spill area was
too small for the number of containers stored within it. [15 NCAC 0202 (b)(2)].

NESHAP - 40 CFR Part 63 Subpart M 63.322
(o)(1)(i) Failure to conduct monthly halogen detector vapor leak inspections while the components are in operation [63.322(o)(1)(i)].
RCRA- Hazardous Waste Regulations: 40 CFR Part 261 - 262 None

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(VI) ENFORCEMENT HISTORY (Penalties): None (VII) RECOMMENDATIONS: A DSCA Compliance Program Checklist (#999) was issued to Mr. Brad Robbins, Manager of Boston Cleaners, indicating the compliance issues to be addressed. Mr. Robbins was instructed to respond (or have Mr. James W. Robbins Jr. respond) to DSCA Compliance in writing by December 08, 2022, the actions taken to bring
about compliance. A follow-up inspection should be conducted by November 17, 2023 to confirm compliance. (VIII) PHOTOGRAPHS:

Photo 1: Boston Cleaners

Photo 3: The rear of the dry-cleaning machine

Photo 2: The dry-cleaning machine

Photo 4: The spotting table

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Photo 5: The central vacuum behind the WWTU
Photo 7: The misting nozzle in operation
Photo 6: The Kleen Rite WWTU
Photo 8: The waste storage area

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Photo 9: The waste storage area
Photo 11: The emergency response plan
Photo 10: Box of spill adsorbent material behind WWTU