Respondent is a stand-alone dry cleaning facility that operated three large fourth-generation dry cleaning machines with capacities of 65 lb. and 80 lb.; these machines used Perchloroethylene (Perc) as the dry cleaning solvent. During each of three separate RCRA CEIs conducted of the facility, multiple violations, including failure to minimize releases, were discovered. The CAFO includes a SEP which will result in the facility replacing its Perc machines with green machines.