7/29/09 - NOTICE OF DETERMINATION ISSUED. IN A JULY 24, 2008 LTR TO EPA, LYNN UNIVERSITY DISCLOSED VIOLATIONS OF EPCRA, RCRA, AND CWA. ON NOV 24, 2008, LYNN UNIVERSITY SUBMITTED A FINAL COMPLIANCE REPORT, WHICH CONTAINED ADD'L INFO, INCLUDING THE CORRECTIVE ACTIONS TAKEN.
CWA - SPCC VIOLATIONS:
1. THE SPCC PLAN DID NOT INCLUDE ALL OIL STORAGE LCOATIONS (WITH QUANTITIES 55 GALLONS OR GREATER).
2. THE SPCC PLAN DID NOT INCLUDE A PHYSICAL LAYOUT AND FACILITY DIAGRAM.
3. THE MASTER FLOW, DRAIN VALVES, STARTER CONTROLS, LOADING/UNLOADING CONNECTIONS WERE NOT LOCKED OR SECURED FOR ALL STORAGE CONTAINERS.
4. ANNUAL SPCC TRAINING HAD NOT BEEN GIVEN.
5. SECONDARY CONTAINMENT WAS NOT PROVIDED IN THE MECHANICAL ROOM IN WHICH AN 80-GALLON HYDRAULIC RESERVOIR FOR AN ELEVATOR WAS LOCATED AT THE MAINTENANCE BUILDING, BUILDING NO. 20.
6. SECONDARY CONTAINMENT WAS NOT PROVIDED IN THE MECHANICAL ROOM IN WHICH A 55-GALLON HYDRAULIC RESERVOIR FOR AN ELEVATOR WAS LOCATED AT THE RONALD & KATHLEEN ASSAF ACADEMIC CENTER, BLDG NO. 2.
7. AN ACTIVE LEAK AT THE ELEVATOR EQUIPMENT ROOM IN TRINITY HALL, BLDG NO. 11 WAS NOT PROMPTLY CORRECTED.
8. ONE 116-GALLON CONTAINER OF WASTE KITCHEN GREASE WAS NOT STORED IN SECONDARY CONTAINMENT, AT THE LYNN STUDENT CENTER, BLDG NO. 6.
9. ONE 55-GALLON CONTAINER OF USED OIL WAS NOT STORED IN SECONDARY CONTAINMENT OR LABELED USED OIL IN THE SHOP ROOM AT THE MAINTENANCE BLDG, BLDG NO. 20.
EPCRA VIOLATIONS:
1. THE UNIVERSITY DID NOT FILE AN MSDS FOR TH