4/2/14 - CONSENT AGMT ISSUED, ASSESSING A PENALTY OF $111,300, DUE WITHIN 30 DAYS.
ALLEGATIONS:
ON OCT 30, 2012, ADEM AND EPA CONDUCTED A RCRA COMPLIANCE EVALUATION INSPECTION AT RESPONDENT'S FACILITY. RESPONDENT SUBMITTED A HAZ WASTE GENERATOR NOTIFICATION ON JAN 23, 2012, WHICH CHARACTERIZED THE FACILITY AS AN LQG OF HAZ WASTE. EPA INSPECTOR DETERMINED THAT RESPONDENT WAS ALSO A SQHUW AND A GENERATOR OF USED OIL AT THE TIME OF THE OCT 30, 2012 RCRA CEI. IT WAS OBSERVED THAT RESPONDENT:
1. FAILED TO PLACE HAZ WASTE IN CONTAINERS OR TANKS WITHIN ITS PAINT MIX ROOM, COATING ROOM, AND IN THE AREA OF THE RISER FROM THE UNDERGROUND HAZ WASTE ACCUMULATION TANK.
2. FAILED TO MINIMIZE THE POSSIBILITY OF A RELEASE OF HAZ WASTE DUE TO ITS USE OF CONCRETE SUMPS IN THE PAINT MIX ROOM AND THE COATING ROOM; THE METAL SECONDARY CONTAINMENT SYSTEM FOR THE WATER BASED PAINT MIXERS; AND THE CONDITIONS WITHIN ITS PAINT MIX ROOM, AND IN THE AREA OF THE RISER OF ITS UNDERGROUND HAZ WASTE ACCUMULATION TANK.
3. FAILED TO COMPLY WITH THE APPLICABLE AIR EMISSION REQUIREMENTS FOR MANAGEMENT HAZ WASTE IN ITS UNDERGROUND HAZ WASTE ACCUMULATION TANK.
4. FAILED TO HAVE A LIST OF EMERGENCY EQUIPMETN IN ITS HAZ WASTE CONTINGENCY PLAN.
5. FAILED TO HAVE A CURRENT LIST OF EMERGENCY COORDINATORS AND PHONE NUMBERS AND ADDRESSES IN ITS HAZ WASTE CONTINGENCY PLAN.
6. FAILED TO SUBMIT ITS CONTINGENCY PLAN OR TO HAVE DOCUMNETATION THAT ITS CONTINGENCY PLAN HAD BEEN SUBMITTED, TO LOCAL POL