Respondent illegally exported hazardous waste, failed to prepare manifests when offering hazardous waste for transport, and failed to timely respond to a RCRA 3007 Information request letter.
The Respondent failed to submit notifications to EPA and failed to maintain proper documentation with respect to their export of CRTs. Because of that, the CRTs failed to meet the conditional exclusion from the definition of solid waste/hazardous waste. Therefore, their exports of CRTs constituted exports of hazardous waste. They have since notified EPA and, we expect, are now maintaining the appropriate records to meet the exclusion. Therefore, their exports CRTs no longer constitute exports of hazardous waste. There is no cost associated with the waste minimization since the cost for the notification and recordkeeping is reflected under facility management and information practice.