Parties have entered into a Consent Agreement and Final Order (?CAFO?) that resolves EPA administratiave claims against Waters Technologies Corporation (?Waters?) for alleged violations of Section 3002 of RCRA, 42 U.S.C. ? 6922 and the authorized Massachusetts RCRA regulations. In the administrative action, EPA alleged that Respondent failed to:
(a) comply with standards for the storage of hazardous wastes in tanks; (b) comply with hazardous waste tank air emission regulations (Subpart CC); (c) comply with hazardous waste air emission standards (Subpart BB) for marking/labeling Subpart BB equipment;
(d) comply with hazardous waste air emission standards (Subpart BB) for monitoring valves in light liquid service, heavy liquid service and gas/vapor service, pumps and flanges;
(e) comply with hazardous waste air emission standards (Subpart BB) for open-ended valves and lines; (f) comply with hazardous waste air emission standards (Subpart BB) for pressure relief valves; (g) comply with hazardous waste air emission standards (Subpart BB) for maintaining records; (h) comply with air monitoring methods that fulfill Method 21,
40 C.F.R. Part 60, Appendix A, as referenced by 40 C.F.R. ? 265.1084(d), for the purposes of determining compliance with 40 C.F.R. Subparts BB and CC; and (i) design and operate a hazardous waste management unit to prevent and/or minimize, the possibility of a release of hazardous waste or hazardous waste constituents to air, soil, surface water, or