Region 5 filed a Consent Agreement and Final Order (CAFO) with Panduit Corp., concluding the proceeding against the Respondent for RCRA violations. Panduit Corp. is a metal finisher and performs electroplating of network, power and grounding connectors through tin, nickel, and gold plating lines.
EPA alleged that Panduit failed to obtain a RCRA permit or interim status at its Orland Park and New Lenox, Illinois facilities. EPA�s allegations were based on information and documents provided by Panduit Corp. during three inspections that occurred on
August 12, 2008, December 2, 2009 and on March 8, 2011, in response to pre-filing settlement discussions, to a Request for Information, and to a Pre-Filing Notice and Opportunity to Confer Letter (Pre-Filing Letter). EPA alleged that, based on Panduit Corp.�s failure to comply with certain conditions for the generator exemption, Panduit Corp. became an operator of a hazardous waste storage facility. Specifically, EPA alleged that Respondent failed to place hazardous waste in containers and tanks, and stored hazardous waste in containers and tanks without proper labeling. Furthermore, EPA alleged that Respondent violated the storage facility requirements when it failed to: (1) adequately operate secondary containment; (2) use overfill prevention controls on tanks; (3) obtain written assessments for hazardous waste tanks; and, (4) maintain a contingency plan, training and inspection records. Lastly, EPA alleged that Panduit C