USEPA MULTI-MEDIA INSPECTION, CONDUCTED IN NOV/DEC 1998, UNCOVERED VIOLATIONS OF RCRA AND CWA AT EOS FACILITY. LITIGATION REPORT TO DOJ DESCRIBES SPECIFIC VIOLATIONS, RECOMMENDED PENALTIES AND INJUNCTIVE RELIEF SOUGHT. ON 8-28-01, PRE-FILING NEGOTIATIONS INITIATED.
CD entered 6/2/05.
Injunctive Relief (RCRA)
(1)Within 120 days (by 9/30/05):
(a)install splash protection on Ts 9, 10, 11, or close tanks that have not had splash protection installed;(b) permanently close Ts 15, 19-22, 34;(c)modify the secondary containment system + install splash protection for Ts 29-31
(2)Within 365 days (by 6/1/06):
(a)modify secondary containment for Ts 12-14, 41 and install splash protection on Ts 12, 13;
(b)permanently close Ts 23-25;
(c)either permanently close Ts 50-52 or relocate Ts 50-52 to the secondary containment system for Ts 60, 61 or to the secondary containment system for Ts 29-47;(d)install a secondary containment system for Ts 60,61 or permanently close such tanks;(e)install a secondary containment system for unloading areas A and B