09/29/17 - CONSENT AGMT ISSUED.
ALLEGATIONS:
ON OCT 18-19, 2016, EPA AND ADEM CONDUCTED A CEI . DURING THE CEI, EPA AND ADEM INSPECTORS OBSERVED THE HAZ WASTE STORAGE AREA INSPECTION RECORDS WERE MISSING INSPECTIONS, THE LAST TWO WEEKS OF DEC 2014 AND THE FIRST AND THIRD WEEKS OF JUL 2016. EPA ALLEGES RESPONDENT VIOLATED SECTION 22-30-12(b) OF THE AHWMMA, ALA. CODE 22-30-12(b) (RCRA 3005) BY STORING HAZ WASTE W/OUT A PERMIT OR INTERIM STATUS BECAUSE RESPONDENT FAILED TO MEET A CONDITION OF THE LQG PERMIT EXEMPTION SET FORTH IN ADAM ADMIN CODE r. 335-14-3-.03(5)(a)1.(I) (40 CFR 262.34(a)(1)(I), BY NOT COMPLYING WITH THE INSPECTION REQUIREMENTS OF ADEM ADMIN. CODE r. 335-14-6-.09(5) (40 CFR 265.174).
DURING THE CEI, INSPECTORS OBSERVED:
THE FOLLOWING CONTAINERS OF HAZ WASTE THAT WERE NOT LABELED WITH THE EPA HAZ WASTE NUMBER:
A. AREA 402 LESS THAN 90-DAY HAZ WASTE STORAGE AREA - 2 ROLL OFFS CONTAINING NSQ NALMET WET SOLIDS, 27 55-GAL DRUMS OF EDGE STRIPS AG6844, A 55-GAL DRUM OF AEROSOL CANS AND A 55-GAL DRUM OF DIESEL FUEL WITH WATER; AND
B. NO. 2 WAREHOUSE - A GAYLORD BOX OF DAMAGED LEAD BATTERIES.
EPA ALLEGES THAT RESPONDENT VIOLATED ADEM ADMIN CODE r. 335-14-3-.03(5)(a)3, WHICH REQUIRED A GENERATOR TO LABEL OR CLEARLY MARK EACH CONTAINER AND TANK ACCUMULATING HAZ WASTE ONSITE WITH THE WORDS: HAZARDOUS WASTE AND THE EPA HAZ WASTE NUMBER.
INSPECTORS REVIEWED THE TRAINING RECORDS FOR FACILITY PERSONNEL THAT HANDLE HAZ WASTE AND FOUND THAT EMPLOYEES DID NOT