20220506WilkesboroDriveInClnrs_RPT

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

Facility Identification
Wilkesboro Drive-In Cleaners Facility ID: 970002C EPA Generator ID: NCD982095176 County/FIPS: Wilkes/193 DSCA Cleanup ID: DC970001
Facility Data
Wilkesboro Drive-In Cleaners 513 W. Main St.
Wilkesboro NC 28697 Lat: 36.146329 Long: -81.160494 SIC: 7216 / Dry Cleaning Plants, Except Rugs NAICS: 81232/ Dry Cleaning and Laundry Services (except Coin-Operated) Date of Facility Establishment: 1971
Compliance Data Inspection Date: 5/6/2022 Time In: 09:40 AM Time Out: 10:40 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: 1995 Installation Category: New Consumption Category: Small HW Generator Status: VSQG
Facility Contact Karon Eller 513 W. Main St. Wilkesboro, NC 28697 [phone]
Facility Owner Nancy Benfield 2015 Fairview Cr. Wilkesboro, NC 28697 [phone]
Property Owner Nancy Benfield 2015 Fairview Cr. Wilkesboro, NC 28697 [phone]
Inspector’s Signature:
Date of Signature: 12 May, 2022
Comments:
No receipts or manifests on site during today’s visit. They need to move 2 waste
barrels to spill containment.

(I) DIRECTIONS: From the DSCA offices at Green Square in Raleigh, go west on Peace Street and take the ramp onto Capital Blvd North. Merge onto Wade Ave. and continue on Wade Ave. which becomes I-40 W and go about 62 miles. Keep right at exit 131 to take I-40 W toward Greensboro. Take exit 188 for US-421 N toward Yadkinville/Wilkesboro and
go 49 miles. Take exit 286A for NC-18 N toward Wilkesboro. Turn left onto NC-16/NC-18 N. Turn right onto W. Main St/NC-18/NC-268. The facility is on the right. (II) FACILITY HISTORY: The facility was established by Mr. Gordon Benfield in the early 1970's and was the owner until 1996 when he sold the business to Mr. Cyvett Gurrera. Mr. Gurrera operated the business from 1996 to 2001. Mr. Benfield regained ownership of the facility in 2001. Mrs. Nancy Benfield is the current owner and property owner. The
facility is open from 7:00 a.m. to 5:30 p.m. Monday through Friday and from 9:00 a.m. to noon on Saturday. The facility is stand alone and does not service any pickup stores. Solvent History:
Solvent Dates Used
Perchloroethylene 1971 to Present
Previous Inspections: Date Visit Type Violation Type(s) Worst Violation(s) Action(s) Taken Response Due Received Date Inspector
9/20/2019 Inspection In
Compliance
N/A CHKLST
sent on 9/20/2019
None N/A or
Not Rec'd
Neshonda
Cobbs
3/23/2018 Inspection In Compliance N/A CHKLST sent on 3/23/2018
None N/A or Not Rec'd Neshonda Cobbs
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8/30/2016 Inspection NESHAP NESHAP Recordkeeping Violations
CHKLST sent on 8/30/2016
8/30/2016 8/30/2016 Jack Kitchen
6/26/2014 Inspection NESHAP NESHAP Recordkeeping Violations
CHKLST sent on 6/26/2014
7/24/2014 7/11/2014 Jack Kitchen
5/11/2012 Initial Inspection MMP NESHAP No WWTU records CHKLST sent on 5/11/2012
6/1/2012 5/30/2012 Pam Moore
12/9/2008 Outreach Training Visit
-- -- CAL sent on 12/10/2008
1/9/2009 1/9/2009 Jack Kitchen
Complaints: None DSCA Sampling: None (III) FACILITY CLASSIFICATION: NESHAP INSTALLATION CATEGORY – New: Wilkesboro Drive-In Cleaners utilizes a Fourth-Generation dry-to-dry dry-cleaning machine that was installed in 1995. 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 Forenta Dual 355 1783 -- 1995 7/5/2016 Perchloroethylene removed
2 Dry-to-Dry 4th Union L840 620-B4-0549-C -- 7/7/2016 N/A Perchloroethylene no
NESHAP SOURCE CATEGORY - SMALL: Wilkesboro Drive-In 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
emailed copies of receipts for the past year, Wilkesboro Drive-In Cleaners purchased 30 gallons of perc from Fabriclean Supply Company in the last 12 months.
HAZARDOUS WASTE GENERATOR CATEGORY - VSQG: Wilkesboro Drive-In 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. Wilkesboro Drive-In Cleaners 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, but Ms. Roten did not know where there were kept, so they were not available for review during the inspection visit. Ms Eller sent copies via text message to the inspector on 7 June 2022. Approximately 23 pounds of hazardous waste are
generated per month. In the past 12 months, no facility-generated wastes were transported off site. The last documented waste pickup occurred on 26 March 2020, when a total of 196 pounds of hazardous waste were transported off site (liquid waste). Many full, 15-gallon drums of hazardous waste were observed on site at the time of the inspection
(approx. 600 lbs. See description in report below). The facility utilizes an onsite wastewater treatment unit (WWTU) to dispose of facility-generated contact water. (IV) INSPECTION SUMMARY: On May 06, 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 Wilkesboro Drive-In Cleaners (photo 1). The inspector met with Shannon Roten, store manager, who provided access to
the facility's equipment and available records.
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Dry-Cleaning Machine The facility continues to operate the Union L840 dry-cleaning machine seen in previous inspections (photo 2). The machine
is operated every other day, cleaning an average of 2 loads on those days. The machine has 3 solvent tanks and a total of 47 gallons was observed, combined in all 3 tanks. The facility’s halogen detector (photo 3) was powered on to confirm its operation, but the dry-cleaning machine was not in use during the time of today’s inspection. The separator water for the
dry-cleaning machine is collected in a covered container stored in the rear containment of the machine (photo 4). During the inspection no contact water was observed in this bucket.
Spotting The spotting board is located across from the dry-cleaning machine (photo 5). There was a small bottle labeled for Picrin on the table, and it was empty. The facility had a ¾-full gallon-sized bottle of Picrin on the shelf. According to Ms. Roten, the Picrin spotting agent is rarely used, and she estimated they may use ½ gallon a year. Central Vacuum The central vacuum is found in the front room of the facility, in a rear corner (photo 6). The condensate is collected in a small bin and then treated using their WWTU. The inspector estimated the container held 2 to 3 gallons of condensate at
the time of the inspection. According to Ms. Roten, that water had been there 2 days. Waste Water Treatment Unit
The facility utilizes a KleenRite Mister WWTU that is stored in a windowed storage room to the left of the dry-cleaning machine (photo 7). The last filter change date was documented as 8/18/21 in the compliance calendar. Extra filters were observed onsite (filter receipts sent later), and Ms. Roten says they typically operate the WWTU once per week.
Waste Storage Area The facility has two waste storage areas. The first waste storage area is in the windowed storage room to the left of the dry-
cleaning machine (the same room that houses the WWTU). Two 15-gallon steel waste containers were observed on a containment tray in the area (photo 8). Each of these containers was about ½ full of waste.
The second storage area is in a side storage room. This room is behind, and accessed through, the break room of the facility. In this room were a total of 6 waste containers (photo 9). The large metal, steel container sitting on the floor was empty. Also empty was one of the 15-gallon steel containers sitting on the spill containment platform. Also on this platform were 2 other 15-gallon steel waste containers; one was full, and one was about ½-full. Two full, 15-gallon, steel containers were found sitting on a movable cart. Neither the containers nor the cart was within any type of spill containment. The inspector urged Ms. Roten to have these containers placed in spill containment as soon as possible. He explained the violation and the seriousness of the condition. Ms. Roten said that she understood and would have this done asap.
Miscellaneous and recordkeeping An emergency response plan was posted, and dedicated emergency spill cleanup materials were readily available at the time of the inspection. DSCA Compliance Calendars were kept on site, were readily available for review; and all required
recordkeeping was observed to be predominantly accurate and complete. No solvent purchase receipts, waste manifests, nor other required receipts were available during the inspection. Ms. Shannon Roten said she would have Karon Eller get that information to the inspector ASAP. The facility had a working halogen detector on the premises, and leak-check logs were
completed in the calendar. However, none of the “H” symbols had been circled to denote that a halogen-detector leak check had been performed (photo 10).
Update: Ms. Eller called Mr. Stauber on 7 June, and she explained the delay in getting the docs. She also sent some photos and waste manifest images via text message and some perc purchase and WWTU filter purchase receipts via email that same day. These correspondences satisfied the document requirements and copies are in their facility folder. Additionally, she confirmed that all barrels that contained waste were within adequate spill containment. The following is a summary of Wilkesboro Drive-In 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 dry-cleaning solvent waste disposal invoices was not made available to the Department.
2. A complete three-year history of records of purchase, maintenance, and service of wastewater treatment equipment was not made available to the Department.
3. Spill containment was not installed under and around the waste solvent storage containers.
NESHAP VIOLATIONS - 40 CFR Part 63 Subpart M 1. A complete five-year history of perchloroethylene purchases was not available for review at the time of the inspection.
RCRA VIOLATIONS - Hazardous Waste Regulations: 40 CFR Part 262.34 None (V) CONCLUSIONS: Based on observations documented by the DSCA Inspector(s) during the May 06, 2022 inspection, Wilkesboro Drive-In Cleaners is currently in violation of the following regulations:
MMPs - 15A NCAC 02S.0202
(b)(1) Failure to maintain complete and current invoices for waste disposal [15A NCAC 02S.0202(b)(1)]. Waste manifests are required to be kept on site for three years and available for review. (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
63.324 (d) Failure to maintain a complete five-year history of perchloroethylene purchase receipts on site [63.324(d)].
RCRA- Hazardous Waste Regulations: 40 CFR Part 261 - 262 None
(VI) ENFORCEMENT HISTORY (Penalties): None
(VII) RECOMMENDATIONS: A DSCA Compliance Program Checklist (#03264) was issued to Shannon Roten, manager of Wilkesboro Drive-In Cleaners, indicating the compliance issues to be addressed. Ms. Roten was instructed to respond (or have Karon Eller respond) to DSCA Compliance in writing by May 27, 2022 the actions taken to bring about
compliance at Wilkesboro Drive-In Cleaners. A follow-up inspection should be conducted by May 06, 2023 to confirm DSCA compliance.

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(VIII) PHOTOGRAPHS:

Photo 1: Wilkesboro Drive-in Cleaners

Phot 3: Halogen detector
Photo 2: The dry-cleaning machine

Photo 4: Rear of dry-cleaning machine
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Photo 5: Spotting table and agents
Photo 7: Wastewater treatment unit (WWTU)
Photo 6: Central vacuum
Photo 8: Waste containers stored behind the WWTU
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Photo 9: Second waste storage area located behind the facility’s breakroom
Photo 11: This photo was sent later by the owner showing
all barrels that contain waste are stored within spill containment. She said the barrels still sitting on the floor are empty.

Photo 10: Calendar page from April 2022