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.