THE COMETCO FACILTY CONTAINS A SURFACE IMPOUNDMENT WHICH CON TAINS A THICK LAYER OF CUTTING OILS PRESENT ON ITS SURFACE. THIS CONSTITUTES A VIOLATION OF THE RCRA USED OIL REGULATIONS. 40 C.F.R. PART 279; AND THE ILLINOIS STATE-AUTHORIZED REGULATIONS AT 35 ILL. ADM. CODE PART 739. ADDITIONALLY THE FOLLOWING VIOLATIONS WERE IDENTIFIED AT THIS FACILITY: (1) VIOLATIONS OF THE RCRA HAZARDOUS WASTE STANDARDS RELATING TO GENERATORS, (2) AN UNPERMITTED POINT-SOURCE DISCHARGE PROBABLY FROM THE SETTLING POND, INTO THE CHICAGO RIVER; (3) REPORTING VIOLATIONS OF THE FACILITY'S STORMWATER DISCHARGE PERMIT; AND (4) VIOLATIONS OF THE CFC REGULATIONS UNDER THE CLEAN AIR ACT.
USEPA entered the consent decree in this matter in 7/2003, which will resolve MMMI's violations of RCRA, CAA, CWA, OPA, and TSCA at four separate facilities owned by the company, all located in Chicago, Illinois. Pre-filing negotiations and the settlement have resulted in the following benefits to the environment: (1) the removal of 23,500 gallons of used oil from an illegal surface impoundment, (2) the reduction in 5074 pounds/year of CFCs being vented to the atmosphere, (3) the construction of secondary containment and formulation of spill prevention and countermeasure plans, greatly diminishing the threat that 27,840 gallons of petroleum products could discharge into Chicago-area waterways, and (4) the plugging of an illegal point source discharge, which previously discharged an unknown amount of oil and