Document dY5oO3z8mnvzdRMwBVv0ge456

United States Environmental Protection Agency Region 7 Enforcement and Compliance Assurance Division Air Branch Inspection Report Unannounced Full Compliance Evaluation Metro Express Cleaners and Laundry 122 South Ankeny Boulevard Ankeny, Iowa 50023 FRS# 110002084486 Inspection Date(s): November 17, 2022 Sean Bergin, Inspector, ECAD, Air Branch Authorized for Release by: Tracey Casburn, Air Branch Chief, ECAD 11201 Renner Boulevard Lenexa, Kansas 66219 Page 1 of 5 CONTENTS INSPECTION OVERVIEW ..............................................................................................................3 INSEPCTION OBJECTIVE ...........................................................................................................3 FACILITY CONTACT INFORMATION ..........................................................................................3 FACILITY OVERVIEW ................................................................................................................3 FACILITY OPERATIONS SUMMARY ...........................................................................................4 FIELD ACTIVITIES SUMMARY....................................................................................................4 Measurement and/or Sampling Activities............................................................................5 INSPECTION OBSERVATIONS AND POTENTIAL FINDINGS.............................................................5 TABLES Table 1. PROJECT TEAM MEMBERS .............................................................................................3 Table 2. FACILITY CONTACT INFORMATION.................................................................................3 Table 3. APPLICABLE REGULATIONS AND STANDARDS ................................................................3 Table 4. FIELD MEASUREMENT ACTIVITIES ..................................................................................5 APPENDICES A Request for Documents Response (79 of pages) B Field Photographs (21 pages) This Contents page shows all the sections contained in this report and provides a clear indication of the end of this report. Page 2 of 5 INSPECTION OVERVIEW INSPECTION OBJECTIVE The objective of the full compliance evaluation (FCE) inspection was to determine compliance of the facility with the Clean Air Act, Section 111, New Source Performance Standards (NSPS), and Section 112, Hazardous Air Pollutants, and implementing regulations in the code of federal regulations (CFR). The inspection was part of the U.S. Environmental Protection Agency's (EPA) Creating Cleaner Air for Communities National Enforcement and Compliance Initiative. The inspection was prompted by a request from the EPA Region 7 Superfund Division after a representative of the Division observed a drum of perchloroethylene at the site of the inspection. Table 1 lists the inspection team members. Team Member Sean Bergin Jim Voight Table 1. PROJECT TEAM MEMBERS Organization EPA, Region 7, ECAD, Air Branch Polk County Air Quality Division, Iowa Department of Natural Resources (IDNR) Project Role Lead Inspector Inspector FACILITY CONTACT INFORMATION Table 2 lists the primary facility contacts. Name, Title Keith MacKay, Owner Amber Edwards, Manager Table 2. FACILITY CONTACT INFORMATION Phone No. Email Address (515) 963-9522 keith@reliablemaintenancecompany.com (515) 963-9522 FACILITY OVERVIEW Metro Express operates under a conditional Operating Permit issued by the Polk County Air Quality Division January 6, 2022. Conditional operating permits are issued annually. The facility is permitted as a perchloroethylene dry cleaning area source. There have not been violations in the most recent five years. The facility is subject to the following regulations and standards (Table 3): Code of Federal Regulation 40 CFR Part 60 40 CFR Part 63 Table 3. APPLICABLE REGULATIONS AND STANDARDS Standard Name Subpart A, General Provisions and Subpart JJJ, Standards of Performance for Petroleum Dry Cleaners. Subpart A, General Provisions and Subpart M, National Perchloroethylene Air Emission Standards for Dry Cleaning Facilities. According to 40 CFR 60 Subpart JJJ the facility is required to maintain a record of the performance test. 40 CFR 63 Subpart M requires affected facilities to maintain records of all Page 3 of 5 maintenance, repair, inspections, monitoring, perchloroethylene purchases and consumption, design specifications and operating manuals of the dry-cleaning machine for 5 years. FACILITY OPERATIONS SUMMARY Metro Express operates a laundry and dry-cleaning service. The facility operates one perchloroethylene dry cleaning machine- a dry-to-dry machine with a refrigerated condenser. The site began business operations in 1963 as Reynolds Max Trucking. Camelot Dry Cleaners operated at the site from 1979 to 1996, and Ankeny Dry Cleaners was associated with the property after 2000. Metro Express Dry Cleaning is currently operating at the site. In 2002 the property lessee, Mr. Keith MacKay, contracted Allendar Butzke Engineers Inc. to perform an environmental exploration of the property. Groundwater samples showed that perchloroethylene, trichloroethylene, cis-1,2-dichloroethylene, and vinyl chloride were above IDNR action levels. Annual IDNR sampling events have occurred on the site since 2006. The EPA is at the site to further delineate migration of VOC contamination in soil and groundwater, and to conduct vapor sampling to assess possible vapor intrusion at the site. FIELD ACTIVITIES SUMMARY I arrived at the facility on November 17, 2022, and completed a drive by surveillance inspection. Mr. Voight arrived a short time later and we made entry of the facility at 10:40 a.m. and were greeted by Ms. Edwards, facility manager. I introduced myself and Mr. Voight, presented my credentials, and provided my business card to Ms. Edwards. Ms. Edwards informed me that the owner was out of town. I conducted a brief opening conference during which I explained that the purpose of the visit was to conduct an inspection to determine compliance with the CAA. Specifically, to determine compliance with the conditions listed in Table 3. Ms. Edwards called Mr. MacKay and told him or our arrival. She confirmed to Mr. MacKay that we had leak detecting equipment with us and concluded their call. She told me that Mr. Mackay said to look at whatever we needed to look at. I asked Ms. Edwards if she knew anything about the drycleaning equipment or monitoring of the equipment. She explained that she did not. I asked Ms. Edwards if she had any knowledge of leak testing and repair of the dry-cleaning machine or where the records were kept. Ms. Edwards said that she did not. She said that Mr. MacKay is the only one that uses the equipment, and he operates the dry-cleaning machine at night. I requested Mr. MacKay's email address and asked Ms. Edwards to tell Mr. MacKay that I will be sending him an email or letter with a list of questions about the equipment, equipment monitoring, and required records. Mr Voight and I examined the dry-cleaning machine and took photographs. For the duration of the inspection, I carried a Honeywell ppbRAE 3000+ photoionization device (PID) with a 10.6 eV lamp calibrated with isobutylene (calibration information is noted in the instrument log book). The PID was bump tested just prior to the entering the facility. Site sampling activities are described in the Measurement and/or Sampling Activities section below. I did not conduct a closing conference with Ms. Edwards. No documents were collected during the inspection and a Receipt for Documents was not prepared. A Confidential Business Information form was not provided at the time of the inspection. At the close of the inspection Mr. Voight and I thanked Ms. Edwards for her time and exited the facility at approximately 11:30 a.m. Page 4 of 5 I sent an information request letter to Mr. MacKay on January 9, 2023, to collect monitoring records and information about the equipment and facility. I received the response on February 8, 2023 (Appendix A). Measurement and/or Sampling Activities I conducted sampling for volatile organic chemicals (VOCs) during the onsite inspection. The PID was operating when I entered to site and was used in and around the dry-cleaning machine. The PID was turned off after I exited the facility. After the inspection I was unable to download any data collected during the inspection from the PID. During the inspection I observed the PID many times and the highest observed reading was approximately 7.0 ppm VOCs found at approximately 10:55 a.m. while I was taking readings at the back of the dry-cleaning machine near the Still. Table 4 summarizes field measurement and field sampling activities. All environmental measurement activities were performed in accordance with the EPA Region 7 quality system. Location Identifier Date(s) and Time Table 4. FIELD MEASUREMENT ACTIVITIES Method and/or Procedure1, and Equipment Dry Cleaning Machine 11/17/2022 10:45 to 11:30 Region 7 procedure: Safety and Sample Screening Instruments. Instrument guide(s): Equipment: Honeywell ppbRAE 3000+, Serial No. 594916195 1 The current version of each procedure, at the time of the investigation, was followed. Measurer Name Sean Bergin INSPECTION OBSERVATIONS AND POTENTIAL FINDINGS Ambient weather, site conditions and activities were documented in field records. All photographs are attached as Appendix B. These observations are not final compliance determinations. The EPA Region 7 Air Branch case review team will make the final compliance determinations based on its review of this report and other technical, regulatory, and facility information. No potential findings were identified at the time of the inspection. Page 5 of 5