9/25/18 - CONSENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $7,400, DUE WITHIN 30 DAYS.
ALLEGATIONS:
AS THE OWNER AND OPERATOR OF THIS FACILITY, RESPONDENT PROVIDES ITS CUSTOMERS WITH SPENT SOLVENT RECOVERY SERVICES AND UPON ACQUIRING SPENT SOLVENT FROM ITS CUSTOMERS, RESPONDENT MANAGES IT AS HAZARDOUS WASTE.
ON FEB 15, 2016, RESPONDENT FILED A NOTIFICATION OF HAZARDOUS WASTE ACTIVITY WITH TDEC DESIGNATING THE FACILITY AS A FACILITY WHICH RECEIVES HAZARDOUS WASTES FROM OFF-SITE FACILITIES AND IS PERMITTED TO STORE THOSE HAZARDOUS WASTES AT ITS FACILITY.
ON APR 18, 2017, INSPECTORS WITH EPA AND TDEC CONDUCTED A COMPLIANCE EVALUATION INSPECTION (CEI) AT RESPONDENT'S FACILITY.
DURING THE CEI, INSPECTORS OBSERVED A CLEARLY VISIBLE GAP BETWEEN THE 15-000 GALLON SERVICE CENTER HAZARDOUS WASTE STORAGE TANK AND THE TANK'S MANHOLE COVER WHICH, HAVING BEEN DESIGNED TO FORM A CONTINUOUS BARRIER OVER THE ENTIRE SURFACE ARE OF THE TANK, WAS OPERATING AS THE TANK'S CLOSURE DEVICE.
DURING THE CEI, THE INSPECTORS WERE INFORMED THAT HAZARDOUS WASTES IDENTIFIED WITH EPA HAZARDOUS WASTE NUMBERS D018, D039 AND D040 WERE THEN BEING STORED WITHIN THE AFOREMENTIONED HAZARDOUS WASTE TANK.