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HomeMy WebLinkAbout20200310WilkesHourglassClnrs_RPTNORTH CAROLINA DIVISION OF WASTE MANAGEMENT Dry Cleaning Solvent Cleanup Act (DSCA) Compliance Program Inspection Report Date: 3/24/2020 Facility Identification Wilkes Hourglass Cleaners Facility ID: 970001C EPA Generator ID: NCD981748072 County/FIPS: Wilkes/193 DSCA Cleanup ID: Facility Data Wilkes Hourglass Cleaners 1250 West D St. North Wilkesboro NC 28659 Lat: 36.159635 Long: -81.152844 SIC: 7216 / Dry Cleaning Plants, Except Rugs NAICS: 81232/ Dry Cleaning and Laundry Services (except Coin-Operated) Date of Facility Establishment: 1/1/1968 Compliance Data Inspection Date: 3/10/2020 Time In: 09:58 AM Time Out: 11:55 AM Inspector: John Stauber Operating Status: OO/Operating Compliance Codes: In Violation of NESHAP Action Code: 01/Inspection Contact Data Classification Data Service Type: Full Service (Active) Solvent: Perchloroethylene System: Dry-to-Dry Installation Date: 1999 Installation Category: New Consumption Category: Small HW Generator Status: VSQG Facility Contact Greg Glover 1250 W. D St. North Wilkesboro, NC 28659 (336) 838-3433 Facility Owner Greg & Buddy (Irving Spencer) Glover 1250 W. D St. North Wilkesboro, NC 28659 (336) 838-3433 Property Owner Irving Spencer Glover 1250 W. D St. North Wilkesboro, NC 28659 (336) 838-3433 Inspector’s Signature: Date of Signature: 3/24/2020 Comments: Leak discovered during the inspection. Owner will contact mechanic to repair the leak, and contact us after completion. (I) DIRECTIONS: From the DSCA offices located at Green Square in Raleigh. Travel on Wade Ave until it becomes I- 40 W. Go 62 miles and keep right at exit 131 to take I-40 W toward Greensboro. Take exit 188 for US-421 N toward Yadkinville/Wilkesboro and go 48 miles. Take exit 285 toward Brushy Mtn Rd/Wilkesboro. Turn slight right toward Wilkesboro. Turn slight right onto Oakwoods Rd/NC-1001N and continue to follow Oakwoods Rd for 1.2 miles. Oakwoods Rd becomes Wilkesboro Ave/NC-18/NC-268. Turn slight left onto Wilkesboro Ave/NC-18/NC-268. Turn left onto NC-18/NC-268. Turn left onto D Street/US-421-BR. The facility is on the right. (II) FACILITY HISTORY: The facility was established in 1968 by Irving Spencer Glover (a.k.a Buddy) who is currently co-owner with his son, Greg Glover. The facility is open from 7:30 a.m. to 5:30 p.m. Monday through Friday and from 8:00 a.m. to noon on Saturday. The facility is stand-alone and services one pickup store, Hourglass Cleaners at 106 Wilkesboro Ave, Wilkesboro. Solvent History: Solvent Dates Used Perchloroethylene (perc) 1968 to Present Previous Inspections: Date Visit Type Violation Type(s) Worst Violation(s) Action(s) Taken Response Due Received Date Inspector 9/11/2018 Inspection In Compliance N/A CHKLST sent on 9/11/2018 None N/A Neshonda Cobbs 11/30/2016 Inspection In Compliance N/A CHKLST sent on 11/30/2016 None N/A Jack Kitchen 6/26/2014 Inspection In Compliance not calculating 12- month perc purchase totals each month. Corrected during inspection CHKLST sent on 6/26/2014 None N/A Jack Kitchen 5/11/2012 Initial Inspection -- -- sent on None N/A Pam Moore 12/9/2008 Outreach Training Visit -- -- CAL sent on 12/10/2008 1/9/2009 12/29/2008 Jack Kitchen Complaints: None DSCA Sampling: None (III) FACILITY CLASSIFICATION: NESHAP INSTALLATION CATEGORY – New: Wilkes Hourglass Cleaners utilizes a 4th Generation dry-to-dry dry cleaning machine that was installed in 1999. 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 Union L750 U2000 102A00433C 1999 1999 N/A perc yes 2 Dry-to- Dry 3rd Union Metro M- 35 34E4372 1994 1994 N/A perc no NESHAP SOURCE CATEGORY - SMALL: Wilkes Hourglass 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, Wilkes Hourglass Cleaners purchased 45 gallons of perc from XNS Farrington Supply Company in the last 12 months. HAZARDOUS WASTE GENERATOR CATEGORY - VSQG: Wilkes Hourglass 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. Wilkes Hourglass Cleaners has contracted with MCF Environmental Services 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 30 pounds of hazardous waste are generated per month. In the past 12 months, 300 pounds of facility- generated waste were transported off site. The last waste pickup occurred on December 12, 2019, when a total of 150 pounds of hazardous waste were transported off site (liquid waste). One partially full 15-gallon drum of hazardous waste was observed on site at the time of the inspection (approx. 100 lbs). The facility utilizes an onsite wastewater treatment unit (WWTU) to dispose of facility-generated contact water. (IV) INSPECTION SUMMARY: On March 10, 2020, John Stauber, Compliance Inspector, with the North Carolina Division of Waste Management, Dry Cleaning Solvent Cleanup Act (DSCA) Program, conducted a Compliance Inspection at Wilkes Hourglass Cleaners (Picture 1). Mr. Stauber met with Mr. Glover, store owner, who provided the inspector access to the facility's equipment and available records. Dry-Cleaning Machine The Union L750 dry-cleaning machine is operated beginning at 08:30, 4 days a week, each weekday except Thursday, cleaning an average of two loads per day. The facility has two machines, but they only use the L750 machine (picture 2). Mr. Glover said that it has been 10 years since they’ve operated the Metro M-35 machine (picture 3). The M-35 Machine was connected to power, but free of solvent. There were about 140 litres of clean solvent in the L750 machine. The separator water for the L750 machine is collected at the beginning of each day in a lidded, 5-gallon bucket. The bucket is stored under the drain for the facility’s central clothes-press vacuum pump (picture 4). During the inspection, no condensate was observed. Mr. Glover noted that the separator water had already been collected and treated for the day. Combined, the dry-cleaning machine and the vacuum pump produce about 1 gallon of contact water each day. The refrigerated condenser exit temperature was observed at 36ºF at the end of the drying cycle (picture 5). No spent filters were on site. Solvent waste is pumped directly through a hose to a labeled and sealed, 15-gallon, plastic drum within spill containment, located beside the rear corner of dry-cleaning machine (picture 6). The inspector asked Mr. Glover to demonstrate how he conducts leak checks, using the facility’s halogen detector. While Mr. Glover was sweeping his detector along the top, left section of the machine’s rear, near the access to the cooling system, his detector alerted audibly and visually to the positive detection of perc vapors (area shown in picture 7). The inspector’s halogen detector also signaled (audibly and visually) for the detection of perc at that same area of the machine. Neither of the two halogen detectors signaled positive for the detection of perc vapors at any other area of the machine. The owner remarked that he had just had the cooling coil serviced in the last few days. Access to the cooling coil is within the area noted by the arrow in picture 7. While the inspector was searching and reviewing the facility’s recordkeeping and recording the pertinent information from the facility’s documents, Mr. Glover used a ladder to allow better access to the machine’s top section. While up on the ladder, he traced and found the perc vapor leak. He said that he found a small air leak where the coil assembly’s rear plate seals to the frame of the dry-cleaning machine. He also found a corroded and broken bolt and showed it to the inspector. He suggested that the mechanic had broken the bolt, and the loss of this bolt was keeping the plate from sealing adequately. Mr. Glover said he would contact the mechanic to have him come back and correct the issue. Clothes Press Vacuum Pump The vacuum pump is located to the rear of the Metro machine (picture 4). Water is collected in a 5-gallon bucket. This bucket is also used to collect the water from the dry-cleaning machine. Mr. Glover estimates that the vacuum and the dry- cleaning machine, combined, produce about a gallon of condensate each day. The bucket was not within spill containment. Mr. Glover noted that the bucket is only used for collection. No water is stored in the bucket, and no containment is necessary. Wastewater Treatment Unit The facility utilizes a Kleen-Rite Hydro-Mist wastewater treatment unit (WWTU) (picture 8). The WWTU is located within adequate spill containment, outside in a sheltered area at the rear of the building. The Kleen-Rite’s misting nozzles are located on the top of the unit. There is no remote mister assembly or connecting lines. No water was observed in the treatment unit during the inspection. Mr. Stauber wasn’t able to see the WWTU in operation because the facility’s contact water had already been treated for the day. The last filter change on the WWTU was documented on 7 February, 2020 (picture 9). 3 years of receipts were also available, showing the purchase of replacement filters. Hazardous Waste Storage The waste for the dry-cleaning machine is pumped through a hose into a closed and labelled, 15-gallon drum. The drum is located near the rear corner of the dry-cleaning machine and is stored within containment (picture 6). Additional waste is stored in a containment tray in the side hallway that accesses Mr. Glover’s office. Two filter drums were observed, both empty (picture 10). There was also waste storage along the rear wall of the facility, containing an empty, 15-gallon drum (picture 11). All waste storage barrels were within adequate spill containment. The most recent waste pickup was last month, MCF Environmental Services manifest number 018876040JJK, dated 20 February, 2020. Spotting Table and Agents The spotting area is located along the back wall of the facility, in front of the dry-cleaning machine. It was observed with no waste present. There were no spotting agents containing PCE/TCE. (Picture 12). Required Recordkeeping DSCA Compliance Calendars were kept on site and were available for review. The facility had at least 6 years of compliance calendars in their archives. Note that Mr. Glover calculates and records his monthly total perc purchase value in the back of the calendar instead of on each month’s individual page. (Picture 13). The inspector was allowed to review the files located in one drawer of a file cabinet located within the owner’s office where additional required recordkeeping was available for review, including 5+ years of solvent purchase receipts and 3+ years of waste manifests. All record keeping was very comprehensive and appeared to be accurate. An Emergency Information Sheet was posted (picture 14), and dedicated emergency spill cleanup materials were available (picture 15), located in the hallway with the waste barrels. The following is a summary of Wilkes Hourglass 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 1. The dry cleaning machine was not operated and maintained in accordance with the manufacturer's specifications and recommendations. RCRA VIOLATIONS - Hazardous Waste Regulations: 40 CFR Part 262.34 None (V) CONCLUSIONS: Based on observations documented by the DSCA Inspector(s) during the March 10, 2020 inspection, Wilkes Hourglass Cleaners is currently in violation of the following regulations: MMPs - 15A NCAC 02S.0202 None NESHAP - 40 CFR Part 63 Subpart M 63.322 (d) Failure to operate and maintain a dry cleaning system in accordance w/ manufacturer(s) specifications , and recommendations [63.322(d)]. RCRA- Hazardous Waste Regulations: 40 CFR Part 261 - 262 None (VI) ENFORCEMENT HISTORY (Penalties): None (VII) RECOMMENDATIONS: A DSCA Compliance Program Checklist (#03074) was issued to Greg Glover, owner of Wilkes Hourglass Cleaners, indicating the compliance issues to be addressed. Glover was instructed to respond to DSCA Compliance in writing by March 31, 2020, the actions taken to bring about compliance. A follow-up inspection should be conducted by March 10, 2021 to confirm compliance.