20190920WilkesboroDriveInClnrs_RPT

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: 9/20/2019 Time In: 09:00 AM Time Out: 10:15 AM Inspector: Ne’Shonda Cobbs 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: 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: 9/20/2019
Comments: Facility observed in compliance

(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
3/23/2018 Inspection In Compliance N/A CHKLST sent on 3/23/2018
None N/A or Not Rec'd Ne’Shonda Cobbs
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 4th 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 yes
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 receipts for the past year, Wilkesboro Drive-In Cleaners purchased 45 gallons of perc solvent from Fabriclean and 30 gallons of perc solvent from N.S. Farrington 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 is 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 82 pounds of hazardous waste are generated per month. In the past 12 months, 835 pounds of facility-generated waste was transported off site. The last waste pickup occurred on June 18, 2019, when a total of 390 pounds of filter and liquid hazardous waste was transported off site. Approximately 150 lbs. of hazardous waste were observed on site at the time of the inspection. The facility utilizes a KleenRite mister wastewater treatment
unit (WWTU) to treat facility-generated contact water. (IV) INSPECTION SUMMARY: On September 20, 2019, Ne’Shonda Cobbs, 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. The inspector met with Ms. Karon Eller, facility contact, who provided the inspector access to the facility's equipment and available records. Dry Cleaning Machine The facility operates a Union L840 dry-cleaning machine that utilizes perc solvent. The machine is operated daily cleaning an average of 2-3 loads beginning at 8 am. The facility has 3 solvent tanks with a total max capacity of 107 gallons. During the inspection a total of 69 gallons was observed combined from all 3 tanks. The rear of the dry-cleaning machine was observed with cleaning materials in the still containment. The halogen detector signaled in the area during the inspection when placed over the area. The contact water for the dry-cleaning machine is collected in a cover container stored in the
rear containment of the machine. During the inspection 2 gallons of contact water was observed. According to the owner,
the machine generates 3 gallons of waste water each month. (see pics 2-7) Vacuum Pump
The vacuum pump for the facility is located in the front of the facility in a corner. The condensate is collected in a small bin and then placed in a 5-gallon bucket to be transported to the WWTU. There was no condensate observed during the inspection. According to Ms. Eller, the machine generates an average of 12 gallons of condensate each week. (see pic 8)
WWTU The facility utilizes a KleenRite Mister WWTU that is stored in the rear of the facility. The last filter change was documented on 7/13/19. Extra filters were observed onsite and filter purchase receipts were verified. (see pics 9 & 10) Waste Storage Area The facility has two waste storage areas. The first waste storage area is located in a side storage room to the left of the dry-cleaning machine. Two empty 15-gallon waste drums were observed on a containment tray in the area. The second storage area located in a side storage area behind the break room of the facility. Three ¼ full 15-gallon drums, two empty 15-gallon drums, and one ¾ full 15-gallon drum were all observed on a containment tray in the area. (see pics 11 & 12)
Spotting The spotting area for the facility is located across from the dry-cleaning machine. The area was observed with no condensate present. The facility had ¼ full bottle of Picrin and a full bottle of Picrin observed onsite during the inspection. According
to one of the employees, the spotting agent is rarely used. (see pic 13) Miscellaneous
Adequate spill containment was utilized for all dry-cleaning equipment, solvent storage, and waste solvent storage areas. The spill containment areas appeared to be free of cracks, breaks, or damage. 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 and were readily available for review; with all required recordkeeping observed to be predominantly accurate and complete. Additional required recordkeeping (e.g. solvent purchase receipts, waste manifests, etc.) were also readily available for review 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.
MMP VIOLATIONS - 15A NCAC 02S.0202 None

NESHAP VIOLATIONS - 40 CFR Part 63 Subpart M None

RCRA VIOLATIONS - Hazardous Waste Regulations: 40 CFR Part 262.34 None
(V) CONCLUSIONS: Based on observations documented by the DSCA Inspector during the September 20, 2019 inspection, Wilkesboro Drive-In Cleaners is currently in compliance with the applicable regulations.
MMPs - 15A NCAC 02S.0202 None
NESHAP - 40 CFR Part 63 Subpart M
None

RCRA- Hazardous Waste Regulations: 40 CFR Part 261 - 262 None
(VI) ENFORCEMENT HISTORY (Penalties): None
(VII) RECOMMENDATIONS: A DSCA Compliance Program Checklist (#03081) was issued to Ms. Karon Eller, manager of Wilkesboro Drive-In Cleaners, indicating the facility is currently in compliance (no response required). Ms. Eller was instructed to continue actions to maintain compliance at Wilkesboro Drive-In Cleaners. A follow-up inspection should be conducted by September 20, 2020 to confirm compliance.