Image Technology, Incorporated, at a 2/10/2005 U.S. EPA inspection, was found to be deficient in the following areas:
·Obtaining written assessments regarding the integrity of the hazardous waste storage tank and sump pit (HWST/SP) system
·Having adequate secondary containment for the HWST/SP system
·Inspecting the HWST/SP system daily and document those inspections
·Labeling HWST/SP system components with the words ÂHazardous WasteÂ
·Including the location, description and outline of the capabilities of all emergency equipment in the facilityÂs contingency plan
·Providing a training program for employees who have hazardous waste management duties
The deficiency findings at Image Technology consequently led to a Notice of Violation, filed on 4/1/2005.
After two ATP analyses, made on 12/5/2005 and 2/6/2006, the penalty was calculated at $50,000.