2/10/14 - NOTICE OF DETERMINATION ISSUED. IN A JUNE 10, 2009 LETTER TO EPA, UPS-SCS DISCLOSED THAT IT, AS A PERSON SUBJECT TO RCRA, HAD VIOLATED RCRA BY FAILING TO DETERMINE WHETHER A SOLID WASTE IT GENERATED WAS A HAZARDOUS WASTE AS REQUIRED UNDER 40 CFR 262.11. DURING THE PERIOD OF OCT 14-31, 2008, UPS-SCS HAD OCCASION TO SHIP 17 ROLL-OFF CONTAINERS OF MISCELLANEOUS TRASH FOR DISPOSAL AT A LANDFILL IN OKOLONA, KY. THE SHIPMENTS INCLUDED WASTES SUCH AS CARDBOARD, PAPER, AND PLASTIC BUT ALSO INCLUDED AN UNKNOWN QUANTITY OF WASTE CONTAINER PARTS AND MISCELLANEOUS ELECTRONIC WASTE.
THE DISPOSAL WAS A ONE-TIME EVENT AND VIOLATED THE POLICIES AND PROCEDURES OF UPS-SCS's WASTE REMOVAL PROGRAM. UPON LEARNING OF THE EVENT, A REVIEW OF ALL POLICIES AND PROCEDURES WAS UNDERTAKEN DESIGNED TO DETERMINE THE ROOT CAUSE OF THE VIOLATION AND TO IMPLEMENT SUITABLE CORRECTIVE ACTION WITH ALL EMPLOYEES AND AFFECTED FACILITIES.