On September 23, 2010, the U.S. EPA filed a Combined Administrative Complaint and Consent Agreement and Final Order (CAFO) in resolution of alleged RCRA violations detected during a September 26, 2008, EPA inspection. The Complaint alleges violations of certain conditions of the Respondent's RCRA Hazardous Waste Management Permit, including: 1) failure to properly stack containers of hazardous waste; 2) failure to maintain RCRA training documents at the facility; 3) failure to maintain a written contingency plan at the facility; 4) failure to maintain a closure plan at the facility; 5)failure to maintain an updated cost estimate for closure at the facility; and 6) failure to maintain inspection records at the facility.
The CAFO requires payment of a $6,380 civil penalty, in four quarterly installments, plus interest. The final payment is due within 360 days of the effective date of the CAFO. The CAFO also requires the Respondent to submit certain training documents and its updated cost estimate for facility closure within 30 days of the effective date of the CAFO.