2/5/20 - CONSENT AGREEMENT ISSUED, ASSESSING A ZERO PENALTY.
ON AUG 22, 2011, RESPONDENT NOTIFIED GAEPD THAT IT WAS A GENERATOR OF HAZ WASTE AT THE FACILITY. RESPONDENT DID NOT NOTIFY GAEPD THAT IT WAS STORING HAZ WASTE AT THE WAREHOUSE. RESPONDENT DOES NOT HAVE A PERMIT TO STORE, TREAT, OR DISPOSE OF HAZ WASTE.
ON AUG 15, 2019, EPA AND GAEPD CONDUCTED A COMPLIANCE EVALUATION INSPECTION (CEI) AT THE FACILITY AND THE WAREHOUSE.
INSPECTORS WERE TOLD THAT RESPONDENT WAS STORING APPROX 175,240 POUNDS OF SPENT BLAST MEDIA (SBM) AT THE WAREHOUSE. SBM IS GENERATED FROM THE USE OF BLAST MEDIA TO STRIP PAINT FROM AIRPLANES AND EQUIPMENT WHICH CAN RESULT IN CADMIUM AND CHROMIUM BEING PRESENT IN THE SBM.
RECORDS REVIEWED SHOW RESPONDENT RECEIVED 118,120 POUNDS OF SMB FROM US TECHNOLOGY CORPORATION (UST) IN 2015 AND 57,120 POUNDS FROM UST MEDIA (USTM) IN 2018. THE SBM IS STORED IN CONTAINERS THAT ARE 1-CU YD SUPERSACKS.
THE CONTAINERS STORING SBM WERE NEITHER LABELED NOR DATED.
SOME OF THE CONTAINERS STORING THE SBM WERE OPEN AND/OR RIPPED.
RESPONDENT IS DEVELOPING A NEW FILLER PRODUCT CALLED SF-17. THIS PRODUCT IS A MIXTURE OF 75% CALCIUM CARBONATE AND 25% USTM SBM. THIS FILLER WAS DESIGNED FOR USE IN THE MANUFACTURING OF CULTURED MARBLE AND BATHROOM WALL ENCLOSURES. IN THE DEVELOPMENT OF THIS NEW PRODUCT SF-17, RESPONDENT SHIPPED TWO TRUCKLOADS OF SF-17 TO A CUSTOMER IN TEXAS IN 2018. CUSTOMER RETURNED 1 TRUCKLOAD OF SF-17 DUE TO QUALITY ISSUES. IN ANTICIPATION OF