On September 28, 2004, Region 5 filed an Administrative Complaint and Compliance Order against A & R Mechanical Contractors, Inc.(A & R) located at 711 Kettering Park Drive, Urbana, Illinois. The Region alleged that A & R violated state law by transporting hazardous waste without a hazardous waste manifest and for operating a storage facility without the required RCRA permit. A & R allegedly stored hazardous waste in tanks without a RCRA permit and without complying with RCRA interim status requirements. The Complaint proposes a civil penalty of $12,540.
The University of Illinois, Urbana-Champaign (UI) generated waste lithium bromide solution (LBS) and characterized the LBS as non-hazardous . UI provided an MSDS sheet to the Respondent that stated that the LBS was not a listed RCRA hazardous waste. The Respondent transported the LBS to its facility in order to sell the LBS as a replacement for a commerical product. After failing to find a buyer fo the LBS, the Respondent contacted Safety Kleen for disposal. The LBS waste profile produced by Safety Kleen indicated that the LBS contained chromium at 68 ppm, which would make the LBS a characteristic hazardous waste for chromium content. The Respondent stored the LBS for almost two years prior to disposal. The Respondent was not a generator of hazardous waste prior to the disposal of the LBS and is presently classified by the Illinois Environmental Protection Agency (IEPA) as a Conditionally Exempt Small Quantity G