# TENNESSEE TECHNICAL COATINGS
> **Administrative - Formal** · FY2010 · — · Final Order With Penalty
## Case
- **Activity ID:** `2200000700`
- **Case Number:** 04-2010-4007
- **Type:** Administrative - Formal
- **Lead:** EPA
- **Outcome:** Final Order With Penalty
- **Penalty assessed:** —
- **Cost recovery:** —
- **Compliance action $:** —
- **Multimedia (multi-env):** —
## Defendants
- TENNESSEE TECHNICAL COATINGS CORPORATION (SB) (complaint) (settlement)
## Summary

7/27/10 - CONSENT AGMT AND FINAL ORDER ISSUED, ASSESSING A PENALTY OF $9,000 DUE WITHIN 30 DAYS.

ALLEGATIONS:
 
ON FEB 3, 2009, EPA AND TDEC CONDUCTED A RCRA COMPLIANCE EVALUATION INSPECTION (CEI) OF RESPONDENT'S FACILITY. 

RESPONDENT WAS STORING HAZ WASTE IN 4 CONTAINERS THAT WERE INCORRECTLY LABELED DUE TO HUMAN ERROR WITH THE BEGINNING DATE OF ACCUMULATION. EPA THEREFORE ALLEGES THAT RESPONDENT HAS VIOLATED RCRA 3005 AND TENN CODE ANN 68-212-105(4) FOR STORING HAZ WASTE WITHOUT A PERMIT OR INTERIM STATUS, BECAUSE RESPONDENT FAILED TO MEET THE 40 CFR 262.34(a)(2) AND TENN CODE R. & REGS 1200-1-11-.03(4)(e)2(ii) CONDITION OF THE 40 CFR 262.34(a) PERMIT EXEMPTION.

RESPONDENT WAS STORING UNIVERSAL WASTE (FLUORESCENT LIGHT BULBS) IN SIX OPEN CONTAINERS, AND WAS THEREFORE NOT MANAGING THE UNIVERSAL WASTE LAMPS IN A WAY THAT PREVENTED RELEASES TO THE ENVIRONMENT.  EPA THEREFORE ALLEGES THAT RESPONDENT HAS VIOLATED 40 CFR 273.13(d)(1) AND TENN COMP R. & REGS 1200-1-11-.12(2)(d)4(i)(1).

RESPONDENT DID NOT HAVE AN UPDATED CONTINGENCY PLAN AT THE FACILITY.  EPA THEREFORE ALLEGES THAT RESPONDENT HAS VIOLATED RCRA 3005 AND TENN CODE ANN 68-212-105(4) FOR STORING HAZ WASTE WITHOUT A PERMIT OR INTERIM STATUS, BECAUSE RESPONDENT FAILED TO MEET THE 40 CFR 262.34(a)(4) AND TENN COMP R & REGS 1200-01-11-.03(4)(e)2(iv) CONDITION OF THE 40 CFR 262.34(a) PERMIT EXEMPTION BY NOT COMPLYING WITH 40 CFR 265.54(c) AND TENN COMP R & REGS 1200.01-11-.05(4)(e)3.
 
RESPONDENT DID NOT HAV

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*Source: [EPA ECHO](https://echo.epa.gov/) · AI Analytics · CC0 1.0*