5/6/15 - CONSENT AGMT AND FINAL ORDER ISSUED, ASSESSING A PENALTY OF $12,760, DUE WITHIN 30 DAYS.
ALLEGATIONS:
ON DEC 12, 2013, AN INSPECTION WAS CONDUCTED BY EPA AT RESPONDENT'S FACILITY. AT THE TIME OF INSPECTION, FACILITY WAS IN OPERATION.
- NO PCB MARKINGS WERE OBSERVED ON THE OUTSIDE WALL, WHICH SEPARATES THE IN-PROCESSING AREA FROM THE OFFLOADING/LOADING DOCKS. IN ADDITION, NO PCB MARKINGS WERE OBSERVED OUTSIDE THE SCRAP METAL RECOVERY OVEN BUILDING. THEREFORE, RESPONDENT VIOLATED THE MARKING REQUIREMENTS IN 40 CFR 761.40(a)(10).
- RESPONDENT WAS STORING PCB ITEMS IN THE PCB ANCILLARY STORAGE AREA W/OUT ADEQUATE AISLE SPACE TO ALLOW THE UNOBSTRUCTED MOVEMENT OF PERSONNEL, FIRE PROTECTION EQUIPMENT, SPILL CONTROL EQUIPMENT AND DECONTAMINATION EQUIPMENT. THEREFORE, RESONDENT VIOALTED CONDITION III.G OF THE PCB APPROVAL LETTER.
- AT THE TIME OF THE INSPECTION, IN THE SCRAP METAL RECOVERY OVEN (SMRO) AREA, RESPONDENT WAS STORING PCB CONTAMINATED OIL IN 2 OPEN 55-GAL DRUMS. IN ADDITION, TWO 55-GAL DRUMS WERE OBSERVED WITH AN OPEN FUNNEL PLACED IN THE BUNGHOLE. NO MATERIAL WAS BEING ADDED TO OR REMOVED FRM THE CONTAINERS WHEN THE INSPECTORS OBSERVED THE CONTAINERS. THEREFORE, RESPONDENT VIOLATED PERMIT CONDITION III.1 OF THE PCB APPROVAL LETTER.
PURSUANT TO 40 CFR 761.65(c)(8), ALL PCB ITEMS SHALL BE DATED WITH THE DATE THEY WERE REMOVED FROM SERVICE. AT THE TIME OF THE INSPECTION, RESPONDENT WAS STORING 4 55-GAL DRUMS CONTAINING PCB-CONTAMINATED TRANSFORMER